defendant’s sanity beyond a reasonable doubt.” Id. at 143. This caused the Michigan Court of Appeals to hold that the same burden-shifting framework should be applied to both the insanity and diminished-capacity defenses. See Denton, 360 N.W.2d at 247 (reasoning that because all other procedures for the two defenses were the same, the allocation of the burden of proof should follow suit). In 1994, however, the legislature amended the statutory definition of the insanity defense and shifted the burden of proof entirely to the defendant. Insanity was declared an affirmative defense that the defendant must prove “by a preponderance of the evidence.” Mich. Comp. Laws § 768.21a(3); see 1994 Mich. Pub. Acts 251-52 (containing the 1994 amendments); see also McRunels, 603 N.W.2d at 99-100 (<HOLDING>). Consistent with its earlier decisions, the
holding that the 1994 amendments changed the burden of proof for the defense of insanity holding that the burden of proof is on the claimant holding at trial a criminal defendant has the burden to prove his insanity by a preponderance of the evidence holding that insanity is a complete defense to the criminal charge holding that when congress is silent on the issue of the burden of proof applicable to a common law affirmative defense that does not negate an element of the offense we presume congress intended the defendant to bear the burden of proof of the defense by a preponderance of the evidence