The Michigan Supreme Court ruled in *People v. Tadgerson*, a case that examined the standards for charging prisoners with controlled substance possession when contraband is introduced into their cells by other inmates.
Christopher L. Tadgerson was charged in the 85th District Court with being a prisoner in possession of a controlled substance under MCL 800.281(4). The case arose from an incident where Tadgerson was in his prison cell when a corrections officer observed another prisoner pull something from his pocket and drop it into the slot of Tadgerson's cell door.
According to the court record, the corrections officer saw Tadgerson holding a crumpled piece of paper and demanded that the defendant hand over the item. Notably, Tadgerson had not examined the contents of the paper before the officer intervened. Upon inspection, the officer discovered that the paper contained two orange strips with the number eight written on them.
Laboratory testing revealed that the item contained buprenorphine, commonly known as Suboxone, which is classified as a schedule III controlled substance under federal and state law. Tadgerson did not possess a valid prescription for this medication, which is typically used to treat opioid addiction and requires medical supervision.
The case presented complex factual circumstances regarding drug testing results. Initially, Tadgerson tested positive for Suboxone during a drug screen administered after the incident. However, a subsequent retest returned a negative result for the substance, creating ambiguity about whether Tadgerson had actually consumed any of the contraband.
During the preliminary examination proceedings, the prosecution argued that the prisoner possession of controlled substance charge constitutes a strict-liability offense. This legal position would mean that the state would not need to prove criminal intent or knowledge on Tadgerson's part to secure a conviction.
The case was argued before the Michigan Supreme Court on April 9, 2025, after the court granted an application for leave to appeal. The high court issued its decision on July 21, 2025, though the specific holdings and reasoning are not detailed in the available court records.
The *Tadgerson* case touches on several important areas of criminal law as it applies to incarcerated individuals. Michigan's prisoner possession statute, MCL 800.281(4), criminalizes inmates' possession of controlled substances within correctional facilities. The law is designed to maintain order and safety in prison environments by deterring drug trafficking and use among the incarcerated population.
The circumstances in *Tadgerson* present unique questions about criminal liability when contraband is introduced into a prisoner's cell without their active participation or knowledge. The fact that another prisoner dropped the substance into Tadgerson's cell, and that Tadgerson had not examined the contents before being confronted by the officer, raises questions about the mental state required for conviction under the statute.
The prosecution's argument that the offense constitutes strict liability would eliminate the need to prove that Tadgerson knew he was receiving a controlled substance. Under a strict-liability theory, mere possession would be sufficient for conviction, regardless of the defendant's knowledge or intent.
This legal framework has significant implications for prisoners who may find themselves in possession of contraband through no fault of their own. Prison environments present unique challenges where inmates may have limited control over what enters their living spaces, particularly through common areas like cell door slots.
The conflicting drug test results in the case add another layer of complexity to the proceedings. The initial positive test followed by a negative retest creates questions about whether Tadgerson actually used the substance or merely came into contact with it through handling the paper.
Buprenorphine, the substance found in this case, is a medication commonly used in opioid addiction treatment programs. Its presence in correctional facilities often reflects the ongoing struggle with substance abuse issues among incarcerated populations. The medication can be valuable contraband in prison settings due to its opioid properties.
The Michigan Supreme Court's decision in *Tadgerson* will likely provide guidance for prosecutors and defense attorneys in similar cases involving prisoner possession charges. The ruling may clarify the standards for proving possession in circumstances where contraband enters a prisoner's cell through third-party actions.
The case also highlights broader issues in correctional law enforcement and the challenges of maintaining drug-free prison environments. Correctional facilities must balance security concerns with fair application of criminal laws to inmates who may find themselves in compromising situations beyond their control.
The decision comes as Michigan courts continue to address various aspects of prisoner rights and criminal liability within correctional settings. The outcome may influence how similar cases are prosecuted and defended throughout the state's prison system.