Michigan v. Vaughn

The issue before the Supreme Court was whether Defendant-Appellant Joseph Vaughn was entitled to a new trial because the circuit court closed the courtroom during voir dire in violation of defendant's constitutional rights. In 2002, Defendant was arrested on weapons and attempted murder charges when he shot at a retired police officer and a neighbor. Upon review of the circuit court record, the Supreme Court held that a defendant's right to a public trial is subject to the forfeiture rule articulated in "Michigan v Carines" (597 NW2d 130 (1999)) and that the Court of Appeals erred by concluding that defendant's failure to assert his public trial right necessarily "forecloses the later grant of relief." In applying the "Carines" forfeiture rule to defendant's appeal, however, the Court concluded that defendant was not entitled to a new trial because he did not establish that his forfeited claim of error "seriously affected the fairness, integrity, or public reputation of judicial proceedings." Furthermore, the Court concluded that defendant was not entitled to a new trial on the basis of ineffective assistance of counsel. Accordingly, the Court vacated the Court of Appeals' opinion to the extent that it was inconsistent with this opinion, and affirmed defendant's convictions.View "Michigan v. Vaughn" on Justia Law