Justia Michigan Supreme Court Opinion Summaries

Andrew Czarnecki and Montario Taylor were convicted of first-degree premeditated murder in separate cases. Czarnecki was 19 years old at the time of his crime, while Taylor was 20 years old. Both were sentenced to mandatory life in prison without the possibility of parole (LWOP) as required by Michigan law. They argued that their sentences were unconstitutional under Michigan’s prohibition against cruel or unusual punishment.Czarnecki’s conviction and sentence were affirmed by the Michigan Court of Appeals, which reasoned that the precedent set in People v Hall, which upheld mandatory LWOP for felony murder, remained binding. Taylor’s conviction and sentence were similarly affirmed by the Michigan Court of Appeals, which also relied on Hall and other binding decisions. Both defendants sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court extended its decision in People v Parks, which held that mandatory LWOP for 18-year-olds was unconstitutional, to include individuals who were 19 or 20 years old at the time of their crime. The Court held that mandatory LWOP for 19- and 20-year-olds violates the principle of proportionality and constitutes cruel punishment under the Michigan Constitution. The Court ruled that Czarnecki and Taylor are entitled to individualized sentencing procedures before LWOP can be imposed. The Court reversed the Court of Appeals’ decisions, vacated the defendants’ sentences, and remanded the cases for resentencing in accordance with the new ruling. This decision applies retroactively to cases on collateral review. View "People v. Czarnecki" on Justia Law

The case involves Jeffery S. Armstrong, who was charged with carrying a concealed weapon, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony after police discovered a handgun under the passenger seat of a vehicle in which he was sitting. Corporal Treva Eaton claimed she approached the vehicle because she smelled marijuana emanating from it. Armstrong moved to suppress the gun as evidence, arguing it was obtained through a search that violated the Fourth Amendment.The Wayne Circuit Court ruled that Armstrong was seized when officers surrounded the vehicle and that probable cause was required before ordering him out. The court concluded that the smell of marijuana alone did not establish probable cause to search or justify removing Armstrong from the vehicle and ruled that the plain-view exception did not apply. Consequently, the trial court granted Armstrong’s motion to suppress and dismissed the case.The prosecution appealed, and the Michigan Court of Appeals affirmed the trial court’s decision. The appellate court held that the rule from People v. Kazmierczak, which allowed the smell of marijuana alone to establish probable cause, was superseded by the Michigan Regulation and Taxation of Marihuana Act (MRTMA). The court concluded that the smell of marijuana is no longer necessarily indicative of unlawful activity and that the trial court did not clearly err in finding that the gun was not discovered in plain view.The Michigan Supreme Court reviewed the case and held that the Kazmierczak rule is no longer valid in light of the MRTMA. The court ruled that the smell of marijuana is one factor in the probable-cause determination but is insufficient on its own to support a search. The court affirmed the lower courts' decisions, upholding the suppression of the evidence and the dismissal of the charges against Armstrong. View "People Of Michigan v. Armstrong" on Justia Law

John A. Poole was convicted in 2002 of first-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. He was 18 years old at the time of the crime and was sentenced to life imprisonment without the possibility of parole. The Michigan Court of Appeals affirmed his convictions, and the Michigan Supreme Court denied his application for leave to appeal. Poole filed multiple motions for relief from judgment, which were denied.Following the U.S. Supreme Court's decisions in Miller v. Alabama and Montgomery v. Louisiana, which addressed mandatory life sentences for juveniles, Poole sought relief again. The Michigan Supreme Court remanded the case to the Court of Appeals to determine if Poole was entitled to relief under the state constitution's prohibition on cruel or unusual punishment, as extended to 18-year-olds in People v. Parks. The Court of Appeals held that Parks applied retroactively and vacated Poole's sentence, remanding for resentencing.The Michigan Supreme Court reviewed whether Parks should apply retroactively to cases where the period for direct review had expired. The court held that Parks, which extended Miller's protections to 18-year-olds under the Michigan Constitution, announced a substantive rule and should be applied retroactively. The court overruled the state retroactivity analysis in People v. Carp to the extent it survived Montgomery. The court affirmed the Court of Appeals' decision to vacate Poole's sentence and remanded the case for resentencing under MCL 769.25a. View "People Of Michigan v. Poole" on Justia Law

Praxis Packaging Solutions, operating a manufacturing facility, applied for a tax exemption for its manufacturing equipment under Michigan law. The Township of Byron's assessor denied the application, stating the equipment did not meet the statutory definition of eligible manufacturing personal property (EMPP). The denial notice informed Praxis of its right to appeal to the March Board of Review but did not provide specific deadlines or meeting dates. Praxis's agents contacted the assessor for appeal details but were not informed of the deadlines. Praxis submitted an appeal letter after the Board had adjourned, and the Board did not consider the appeal.The Michigan Tax Tribunal dismissed Praxis's petition for lack of jurisdiction, as Praxis had not first appealed to the Board. The Court of Appeals reversed, holding that the Township's notice did not meet statutory requirements and deprived Praxis of due process, thus vesting the Tribunal with jurisdiction.The Michigan Supreme Court reviewed the case and held that the Township's notice did not violate due process. The Court found that the notice, combined with the separate notice of assessment, provided sufficient information about the appeal process. The Court emphasized that due process requires notice reasonably calculated to inform the taxpayer and provide an opportunity to be heard. Since Praxis received actual notice of the Board's meeting dates and the appeal process, the Court concluded that there was no due process violation.The Supreme Court reversed the Court of Appeals judgment and reinstated the Tax Tribunal's dismissal of Praxis's petition for lack of jurisdiction, as Praxis failed to timely protest the exemption denial before the Board. View "Sixarp LLC v. Township Of Byron" on Justia Law

In 2015, the defendant drove his vehicle on a freeway while speeding and under the influence of alcohol and controlled substances. He struck the back of another vehicle, resulting in the deaths of two individuals and serious injuries to three others. The defendant was convicted by a jury in the Genesee Circuit Court of multiple charges, including two counts of involuntary manslaughter and two counts of reckless driving causing death.On direct appeal, the defendant argued for the first time that his convictions violated the multiple-punishments strand of double jeopardy, specifically challenging the convictions for both involuntary manslaughter and reckless driving causing death. The Michigan Court of Appeals affirmed the defendant’s convictions.The Michigan Supreme Court reviewed the case and held that under Michigan common law, the mens rea requirement for reckless driving causing death (willful or wanton disregard) is the same as the mens rea requirement for involuntary manslaughter (criminal gross negligence). Therefore, when an involuntary manslaughter charge is based on a theory of gross negligence, the offense does not have an element that reckless driving causing death does not have. Consequently, the Double Jeopardy Clauses of the United States and Michigan Constitutions prohibit convicting a defendant of both offenses. The Court reversed the judgment of the Court of Appeals and remanded the case to the trial court to determine the appropriate remedy for the double-jeopardy violation. View "People of Michigan v. Fredell" on Justia Law

The case involves a dispute over the issuance of medical marijuana dispensary licenses in the city of Warren. In 2019, the Warren City Council adopted an ordinance to regulate these licenses, which involved a Review Committee scoring and ranking applications. The Review Committee held 16 closed meetings to review 65 applications and made recommendations to the city council, which then approved the top 15 applicants without further discussion. Plaintiffs, who were denied licenses, sued, alleging violations of the Open Meetings Act (OMA) and due process.The Macomb Circuit Court found that the Review Committee violated the OMA and invalidated the licenses issued by the city council. The court held that the Review Committee was a public body subject to the OMA and that the city council's approval process was flawed. Defendants and intervening defendants appealed, and the Michigan Court of Appeals reversed the trial court's decision. The appellate court held that the Review Committee was not a public body under the OMA because it only had an advisory role, and the city council retained final decision-making authority. The appellate court also upheld the trial court's dismissal of the plaintiffs' due process claims.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the Review Committee was a public body subject to the OMA because it effectively decided which applicants would receive licenses by scoring and ranking them, and the city council merely adopted these recommendations without independent consideration. The court emphasized that the actual operation of the Review Committee, rather than just the language of the ordinance, determined its status as a public body. The case was remanded to the Court of Appeals to consider whether the open meetings held by the Review Committee cured the OMA violations and to address other preserved issues. View "Pinebrook Warren LLC v. City Of Warren" on Justia Law

In 2018, Michigan's Legislature received initiative petitions proposing the Improved Workforce Opportunity Wage Act and the Earned Sick Time Act. The Legislature adopted these initiatives without changes, preventing them from appearing on the ballot. However, during the lame duck session after the election, the Legislature significantly amended both laws, effectively nullifying their original intent.The plaintiffs challenged these amendments in the Court of Claims, arguing they were unconstitutional under Article 2, § 9 of the Michigan Constitution. The Court of Claims agreed, ruling that the Legislature could not adopt and then amend an initiative in the same session. The court declared the amendments void and reinstated the original initiatives. The state appealed, and the Court of Appeals reversed the decision, holding that the Legislature could amend an initiative in the same session since the Constitution did not explicitly prohibit it.The Michigan Supreme Court reviewed the case and held that Article 2, § 9 provides the Legislature with only three options upon receiving a valid initiative petition: adopt it without change, reject it, or propose an alternative to be voted on alongside the original. The Court ruled that adopting and then amending an initiative in the same session violated the people's right to propose and enact laws through the initiative process. Consequently, the amendments were declared unconstitutional. The Court ordered that the original initiatives would go into effect 205 days after the opinion's publication, with adjustments for inflation and a revised schedule for minimum wage increases. The Court of Appeals' judgment was reversed. View "Mothering Justice v. Attorney General" on Justia Law

The defendant was convicted by a jury in the Wayne Circuit Court of three counts of torture, three counts of unlawful imprisonment, one count of felonious assault, and one count of possession of a firearm during the commission of a felony. The defendant held his wife and their two children at gunpoint in their home, threatening to kill them and burn down the house. The court sentenced the defendant to various prison terms for these convictions and placed him on the sex-offender registry as a Tier I offender under the Sex Offenders Registration Act (SORA) because two of the unlawful imprisonment convictions involved minors.The defendant appealed his convictions, arguing insufficient evidence for the torture convictions and that his placement on the sex-offender registry violated constitutional protections against cruel or unusual punishment. The Michigan Court of Appeals affirmed the convictions but remanded the case to remove the defendant from the sex-offender registry, concluding that imposing SORA for a crime lacking a sexual component constituted cruel or unusual punishment under the Michigan Constitution. The defendant sought further appeal, and the prosecution cross-appealed regarding the removal from SORA.The Michigan Supreme Court reviewed the case and held that the application of SORA to non-sexual offenders like the defendant constitutes cruel or unusual punishment under the Michigan Constitution. The Court found that the 2021 SORA, despite legislative intent as a civil regulation, imposed punitive effects that outweighed this intent when applied to non-sexual offenders. The Court emphasized that the registry's requirements and the social stigma attached to being labeled a sex offender were excessive and not rationally related to the nonpunitive purpose of public safety. Consequently, the Court vacated the part of the Court of Appeals opinion that extended beyond non-sexual offenders and affirmed the judgment that the defendant and similar offenders should be removed from the sex-offender registry. View "People Of Michigan v. Lymon" on Justia Law

Karen Carter filed a lawsuit against DTN Management Company after she slipped and fell on an icy sidewalk at her apartment complex on January 10, 2018. She alleged negligence and breach of statutory duties. Carter filed her complaint on April 13, 2021. DTN Management moved for summary disposition, arguing that the claim was time-barred by the three-year statute of limitations. The trial court agreed and granted the motion.The Court of Appeals reversed the trial court's decision, holding that Administrative Order No. 2020-3, which extended certain filing deadlines during the COVID-19 state of emergency, was within the Michigan Supreme Court's authority. The appellate court found that the order excluded days from the computation of time under MCR 1.108, making Carter's filing timely. DTN Management appealed to the Michigan Supreme Court.The Michigan Supreme Court held that Administrative Orders 2020-3 and 2020-18 were constitutional exercises of the Court's authority under Const 1963, art 6, §§ 4 and 5. The Court determined that these orders affected the computation of time rather than tolling the statute of limitations, which is within the Court's power to regulate practice and procedure. The Court concluded that Carter's lawsuit was timely filed, as the days during the state of emergency were not counted in the limitations period. Consequently, the trial court's grant of summary disposition was improper. The Court of Appeals judgment was affirmed, and the case was remanded to the Ingham Circuit Court for further proceedings. View "Carter V DTN Management Company" on Justia Law

In the first case, Kent County foreclosed on the homes of Matthew Schafer and Harry and Lilly Hucklebury for unpaid taxes. The properties were sold at auction in 2017, and the county retained the surplus proceeds beyond the owed taxes. Following the Michigan Supreme Court's 2020 decision in Rafaeli, LLC v Oakland Co, which held that retaining surplus proceeds from tax-foreclosure sales is an unconstitutional taking, the Schafer plaintiffs filed a lawsuit seeking those proceeds. The Kent Circuit Court denied the county's motion to dismiss, ruling that Rafaeli applied retroactively. The Court of Appeals affirmed this decision.In the second case, the state of Michigan, acting as the foreclosing governmental unit (FGU) for Shiawassee County, foreclosed on property owned by Lynette Hathon and Amy Jo Denkins in 2018. The state retained the surplus proceeds from the sale. The Hathon plaintiffs filed a class action lawsuit in the Court of Claims, which certified the class and denied the state's motion for summary disposition. After Rafaeli, the plaintiffs moved for summary disposition, and the state moved to revoke class certification. The Court of Claims granted the state's motion to revoke class certification but later recertified an amended class. The Court of Appeals affirmed the Court of Claims' decisions.The Michigan Supreme Court held that Rafaeli applies retroactively to claims not yet final as of July 17, 2020. The court also ruled that MCL 211.78t, which provides a procedure for processing claims under Rafaeli, applies retroactively, while the new two-year limitations period in MCL 211.78l applies prospectively. Claims that arose before December 22, 2020, but expired between that date and the court's decision must be allowed to proceed if filed within a reasonable time. The court affirmed the Court of Appeals' decision in Schafer and remanded the case for further proceedings. In Hathon, the court vacated the Court of Appeals' judgment affirming class recertification and remanded the case to the Court of Claims for reconsideration. View "Schafer v. Kent County" on Justia Law