The Michigan Supreme Court issued a decision July 14, 2025, in *People of Michigan v. Carl Thomas Masi*, a criminal case involving multiple counts of sexual assault against minors that raised important questions about the scope of Michigan's rape-shield statute.
Carl T. Masi was bound over to the Macomb Circuit Court on 12 counts of first-degree criminal sexual conduct under MCL 750.520b and four counts of second-degree criminal sexual conduct under MCL 750.520c. The charges involved alleged acts against three complainants identified as AU, SU, and MU. According to court records, the complainants began living with defendant as minor children, and each alleged that defendant began sexually assaulting them during that time.
The case centered on a critical evidentiary dispute that would test the boundaries of Michigan's rape-shield protections. Defendant Masi sought to admit several pieces of evidence related to the complainants' sexual histories, including evidence that complainant AU had viewed pornography during the course of prior sexual abuse committed by a third party, specifically AU's uncle. This evidence request put the court at the intersection of defendant's rights to present evidence and statutory protections for sexual assault victims.
Circuit Court Judge James M. Biernat Jr. denied defendant's motion to admit the evidence. The trial court concluded that evidence showing AU viewed pornography during alleged prior sexual abuse constituted "sexual conduct" that fell under Michigan's rape-shield statute, MCL 750.520j. The judge determined the evidence was inadmissible under the precedent established in *People v. Morse*.
Michigan's rape-shield statute is designed to protect sexual assault victims from having their sexual history used against them in court proceedings. The statute generally prohibits the admission of evidence regarding a complainant's sexual conduct or reputation, with limited exceptions. Courts must carefully balance these protections against a defendant's constitutional right to present a defense.
The evidentiary ruling represented a significant legal question about what constitutes "sexual conduct" under Michigan law. The distinction matters because evidence that falls within the statute's definition faces much higher barriers to admission. Defense attorneys argued the evidence was relevant to their case, while prosecutors likely contended it would unfairly prejudice the jury against the complainants.
The Michigan Supreme Court heard oral arguments on the application for leave to appeal on March 12, 2025, before issuing its decision four months later. The court's decision to grant leave to appeal and issue a full opinion suggests the justices viewed the case as presenting important legal questions that required clarification.
The case comes as courts nationwide grapple with evolving understandings of sexual assault evidence and victim protections. Rape-shield statutes have been refined over decades to prevent the re-victimization of complainants while preserving fundamental due process rights for defendants. Michigan's statute reflects this balance by creating a presumption against admitting sexual history evidence while allowing exceptions in certain circumstances.
First-degree criminal sexual conduct in Michigan is among the most serious felony charges in the state's criminal code, carrying potential sentences of up to life in prison. The charges require proof of sexual penetration combined with aggravating circumstances such as the victim being under 13 years old or the defendant being in a position of authority over the victim. Second-degree criminal sexual conduct involves sexual contact rather than penetration but still carries substantial penalties.
Cases involving multiple minor victims present particular challenges for courts, prosecutors, and defense attorneys. The evidence often involves testimony from child witnesses, complex family dynamics, and sensitive psychological factors. Courts must navigate these cases with special care to protect vulnerable witnesses while ensuring fair proceedings.
The Supreme Court's decision in *Masi* will likely provide guidance for trial courts statewide in similar cases. Lower courts regularly face difficult evidentiary decisions in sexual assault cases, and clear precedent helps ensure consistent application of rape-shield protections.
The case also highlights the ongoing legal complexity surrounding evidence of prior sexual abuse by third parties. Such evidence can be relevant to a defendant's case but also risks unfairly prejudicing juries against complainants who have already suffered trauma.
Legal observers will likely analyze the Supreme Court's reasoning to understand how Michigan courts should approach similar evidentiary questions in future cases. The decision may influence how defense attorneys craft their strategies and how prosecutors prepare their cases in sexual assault prosecutions.
The *Masi* decision represents another chapter in Michigan's evolving jurisprudence on sexual assault evidence and victim protections, with implications extending beyond this individual case to the broader administration of justice in sexual violence prosecutions throughout the state.