Justia Michigan Supreme Court Opinion Summaries

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

This case presented the question of whether Defendant Ramon Bryant was denied his Sixth Amendment right to an impartial jury drawn from a fair cross section of the community. A fair-cross-section claim under the Sixth Amendment requires a defendant to make a prima facie case as set forth by the United States Supreme Court in "Duren v Missouri," (439 U.S. 357 (1979)). The Court of Appeals concluded that defendant had satisfied the three Duren prongs, establishing a violation of his right to an impartial jury drawn from a fair cross section of the community, and granted defendant a new trial. In its review, the Michigan Supreme Court concluded that the Court of Appeals erred because defendant failed to show under the second prong that the representation of African-Americans in venires from which juries were selected was not fair and reasonable in relation to the number of African-Americans in the community. The Court held "that when applying all the relevant tests for evaluating the representation data, a court must examine the composition of jury pools or venires over time using the most reliable data available to determine whether representation of a distinct group is fair and reasonable. Having considered the results of these tests using the most reliable data set, which included the composition of jury pools or venires over a three-month period, [the Court concluded] that defendant failed to show that the representation of African-Americans was not fair and reasonable." View "Michigan v. Bryant" on Justia Law

Plaintiff Pamela Mattison, gave birth to twins who were conceived by artificial insemination after their father, Jeffery Mattison, had died. She sought social security survivors' benefits for the children based on Jeffery's earnings. The Social Security Administration denied her application, and an administrative law judge affirmed that decision. Plaintiff then filed an action in the United States District Court for the Western District of Michigan challenging the decision. That court has asked the Michigan Supreme Court to rule on whether the children could inherit from Jeffery under Michigan intestacy law. Having heard oral argument, the Supreme Court granted the district court's request to answer the question and held that under Michigan intestacy law, plaintiff's children could not inherit from Jeffery. The matter was returned to the district court for further proceedings. View "In re Mattison v. Social Security Comm." on Justia Law

Jacob Trakhtenberg was convicted of three counts of second-degree criminal sexual conduct. The charges stemmed from allegations of sexual contact made by defendant's then 8-year-old daughter. The issue before the Supreme Court in this case was whether collateral estoppel could be applied to preclude review of defendant's claim of ineffective assistance of counsel when a prior civil judgment held that defense counsel's performance did not amount to malpractice. Upon review, the Supreme Court concluded that collateral estoppels may not be applied in these circumstances because defendant did not have a full and fair opportunity to litigate his ineffective-assistance-of-counsel claim. Given this conclusion, the Court concluded further that defense counsel's performance was constitutionally deficient because she failed to exercise reasonable professional judgment when she decided to forgo any investigation of the case before settling on a defense strategy. "That deficiency prejudiced defendant by undermining the reliability of the outcome of his trial, which rested solely on the credibility of the complainant and defendant." Accordingly, the Court reversed the judgment of the Court of Appeals and remanded this case to the trial court for a new trial. View "Michigan v. Trakhtenberg" on Justia Law

Defendant Kurtis Minch pled guilty to possessing a short-barreled shotgun and possessing a firearm during the commission of a felony. The issue before the Supreme Court in this case was whether Michigan's "felon in possession" statute prevents a police department from delivering lawfully seized noncontraband firearms to the designated agent of a convicted felon. The Court concluded that it does. "The statute does not, however, prevent a court from appointing a successor bailee to maintain possession of a defendant's weapons during his or her period of legal incapacity." View "Michigan v. Minch" on Justia Law

The issue before the Supreme Court in this case was whether defendant was properly convicted of first degree criminal sexual assault under MCL 750.520b(1)(b)(ii), which requires that a defendant be related to the victim "by blood." It was undisputed that defendant Jason Zajaczkowski was not related to the victim, but the prosecution asserted that a civil presumption of legitimacy had been met, thereby establishing the relationship "by blood" for the purposes of the conviction. Upon review of the civil presumption of legitimacy implicated by Michigan statutory and caselaw, the Supreme Court concluded that the prosecution could not establish that a blood relationship between the defendant in this case and his victim. "Moreover, the presumption of legitimacy cannot be substituted for a blood relationship in order to fulfill this element of the crime charged." Accordingly, the vacated defendant's conviction for first-degree criminal sexual conduct, and remanded the case for entry of a conviction of third-degree criminal sexual conduct in accordance with defendant's plea agreement, and for resentencing. View "Michigan v. Zajaczkowski" on Justia Law

Defendant Ryan Bylsma, a registered primary caregiver under the Michigan Medical Marijuana Act (MMMA), was charged with manufacturing marijuana in violation of state law. Defendant moved to dismiss the charge, asserting that he was the registered primary caregiver of two registered, qualifying patients, and was allowed to possess the numerous plants ultimately seized by police from a building that belonged to other registered primary caregivers and registered patients whom defendant offered help in growing and cultivating the plants. The trial court denied defendant's motion, holding that the statute has a strict limit of how many plants a registered caregiver may possess, and allows only one person to have access to the facility in which the plants were grown. The issue before the Supreme Court was whether the MMMA provides a registered primary caregiver immunity when growing plants collectively with other registered primary caregivers and their qualifying patients. The Court held that a portion of the MMMA did not contemplate collective action, and as such, defendant was not entitled to its grant of immunity from arrest, prosecution or penalty. Though defendant's argument failed with regard to immunity, the Court determined that the appellate court erred in not considering defendant's affirmative defense argument under a separate section of the MMMA. The Court reversed that portion of the appellate court's decision and remanded the case to the trial court for further proceedings. View "Michigan v. Bylsma" on Justia Law

In two consolidated cases, the issue central to both involved MCL 768.27a(1). In relevant part, in a criminal case in which the defendant is accused of committing a listed offense against a minor, evidence that the defendant committed another listed offense against a minor is admissible and may be considered for its bearing on any matter to which it may be relevant. Upon review of these cases, the Supreme Court concluded that MCL 768.27a "irreconcilably" conflicted with the Michigan Rules of Evidence 404(b). Further, the Court held that evidence admissible under MCL 768.27a remains subject to MRE 403, which provided that a court may exclude relevant evidence if the danger of unfair prejudice, among other considerations, outweighs the evidence's probative value. "In applying the balancing test in MRE 403 to evidence admissible under MCL 768.27a, . . . courts must weigh the propensity inference in favor of the evidence's probative value rather than its prejudicial effect."View "Michigan v. Pullen" on Justia Law

The Supreme Court granted leave in three cases to consider the substantive and procedural aspects of the affirmative defense of medical use of marijuana under section 8, MCL 333.26428, of the Michigan Medical Marihuana Act (MMMA). Given the plain language of the statute, the Court held that a defendant asserting the section 8 affirmative defense is not required to establish the requirements of section 4, MCL 333.26424, which pertains to broader immunity granted by the Act. The Court of Appeals erred by reaching the opposite conclusion in "People v King," and the Court therefore reversed the Court of Appeals’ judgment in that case. Further, to establish the affirmative defense under section 8, the Court held that a defendant must show under section 8(a)(1) that the physician’s statement was made after enactment of the MMMA but before commission of the offense. View "Michigan v. Kolanek" on Justia Law

This case involved a policy for uninsured-motorist (UM) coverage issued by Defendant State Farm Mutual Automobile Insurance Company which contained a 30-day notice provision regarding hit-and-run motor vehicle claims. Upon review, the Court held that an unambiguous notice-of-claim provision setting forth a specified period within which notice must be provided is enforceable without a showing that the failure to comply with the provision prejudiced the insurer. Therefore, State Farm properly denied the claim for UM benefits sought in the instant case because it did not receive timely notice, a condition precedent to the policy's enforcement. In this case, the Court reversed the judgment of the Court of Appeals and remanded the case to the trial court for entry of summary disposition in favor of State Farm.View "DeFrain v. State Farm Mutual Automobile Ins. Co." on Justia Law