People v. Hawthorne

The issue in this case is whether a court’s failure to instruct on the defense of accident requires automatic reversal of a defendant’s conviction where accident was a central issue in the case. We hold that the failure to instruct on this defense requires reversal only where the defendant satisfies the standard explicated in People v Lukity, 460 Mich 484; 596 NW2d 607 (1999), and People v Rodriguez, 463 Mich 466, 474; 620 NW2d 13 (2000).1 In this case, defendant has not established that the alleged error undermined the reliability of the verdict. We therefore reverse the judgment of the…