capacity was well-established under Michigan law prior to Carpenter a. Michigan Court of Appeals Diminished capacity was first recognized as a defense in People v. Lynch, 47 Mich.App. 8, 208 N.W.2d 656 (1973), 28 years before Carpenter was decided. The court in Lynch held that the trial court erred in prohibiting the defendant charged with first-degree murder from presenting medical evidence “of diminished or partial responsibility.” Id. at 662; see also Carpenter, 627 N.W.2d at 281 (recognizing that Lynch “introduced to Michigan the diminished capacity defense” as a “defense separate from legal insanity”). Then, in 1975, the Michigan legislature enacted a statutory framework for the defense of insanity. See People v. Mangiapane, 85 Mich.App. 379, 271 N.W.2d 240, 246-49 (1978) (<HOLDING>). One of the newly enacted statutes codified
holding that 1975 public act nos 179 and 180 modified the rule established in lynch recognizing that public utilities affect the public interest in that they render essential public services to a large number of the general public recognizing rule holding district court need not make findings and conclusions as required by rule 52a because under rule 81a3 that requirement could be modified by issuing an order holding the right to record police activity on public property was not clearly established