Justia Michigan Supreme Court Opinion Summaries

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

The issue before the Supreme Court was whether the death of a coperpetrator of a crime may be scored under offense variable (OV) 3, MCL 777.33, which concerns "physical injury to a victim." Upon review, the Court concluded that a coperpetrator is properly considered a "victim" for purposes of OV 3 when he or she is harmed by the criminal actions of the charged party, in this case, Defendant Marteez Laidler. Because the Court concluded that the coperpetrator's death constituted such a harm, the Court reversed in part the judgment of the Court of Appeals and reinstated Defendant's sentence. The trial court properly assessed 100 points for OV 3 because the coperpetrator was harmed by the criminal actions of Defendant.View "Michigan v. Laidler" on Justia Law

In four cases, each involving a ballot proposal to amend the Michigan Constitution, the issue before the Supreme Court was whether the groups proposing the amendments properly exercised their right to petition for constitutional amendments in compliance with the constitutional and statutory safeguards. Upon review of the cases, the Court reaffirmed prior caselaw holding that an existing provision is only altered when the amendment actually adds to, deletes from, or changes the wording of the provision. Furthermore, the Court reaffirmed that an amendment only abrogates an existing provision when it renders that provision wholly inoperative. Applying the meanings of "alter" and "abrogate" to the cases at issue, the Court concluded that none of the ballot proposals altered an existing provision of the Constitution because none of them actually "add to, delete from, or change the existing wording of the provision . . . ." View "Protect Our Jobs v. Bd. of State Canvassers" on Justia Law

Defendant Shawn Thomas Brown pled guilty to second-degree home invasion as a second-offense habitual offender. He was not informed by the court of his maximum possible sentence as an habitual offender before the plea was accepted. Rather, Defendant had been informed that the maximum penalty for the home-invasion offense was 15 years in prison, but he was ultimately sentenced to a prison term of 6 years and 3 months to 22 years and 6 months in accordance with the habitual offender enhancement. Defendant did not object at sentencing, but later moved to withdraw his plea or for resentencing, which the court denied. Defendant appealed. Upon review, the Supreme Court concluded that there was a clear defect in the plea proceeding in this case, and defendant’s plea was not an understanding plea as required by MCR 6.302(B)(2) because he was not properly informed of the potential maximum sentence for second-degree home invasion as enhanced by his second-offense habitual-offender status before his plea was accepted. Accordingly the case was remanded for further proceedings. View "Michigan v. Brown" on Justia Law

Plaintiff Stand Up for Democracy petitioned the Supreme Court for a writ of mandamus to compel the Board of State Canvassers to certify its referendum petition for inclusion on the November 2012 ballot. Intervening defendant Citizens for Fiscal Responsibility, challenged the certification of plaintiff’s referendum petition, alleging that it failed to comply with the type-size requirement of MCL 168.482(2) and that the doctrine of substantial compliance, whereby technical deficiencies are resolved in favor of certification, did not apply. The Court of Appeals agreed with both assertions, but concluded it was required to follow its decision in "Bloomfield Charter Township v Oakland County Clerk" and conclude that the petition substantially complied with MCL 168.482(2) and that certification was required. Upon review, the Supreme Court reversed, overturning "Bloomfield Charter" and dismissed the case: "because MCL 168.482(2) uses the mandatory term 'shall' and does not, by its plain terms, permit certification of deficient petitions with regard to form or content, a majority of [the] Court [held] that the doctrine of substantial compliance is inapplicable to referendum petitions submitted for certification." View "Stand Up for Democracy v. Mich. Sec'y of State" on Justia Law

These three cases involved the felony of failure to pay court-ordered child support (felony nonsupport) under MCL 750.165 and the rule of "Michigan v. Adams." The Supreme Court granted leave to consider the constitutionality of the Court of Appeals' ruling in "Adams" and now clarified that, while inability to pay is not a defense to felony nonsupport pursuant to MCL 750.165, "Adams" does not preclude criminal defendants from proffering the common-law defense of impossibility. The Court endorsed the well-established common-law defense of impossibility as the proper defense to felony nonsupport. "Consistently with the Legislature's expressed intent in the child support statutes, [the Court] believe[d] that to avoid conviction for felony nonsupport, parents should be required to have done everything possible to provide for their child and to have arranged their finances in a way that prioritized their parental responsibility so that the child does not become a public charge." View "Michigan v. Likine" on Justia Law

The issue before the Supreme Court in this case was whether newly discovered impeachment evidence could constitute grounds for a new trial and, if so, under what circumstances. Defendant sought a retrial on the basis of newly discovered impeachment evidence. The trial court and the Court of Appeals concluded that this evidence could not be used as a basis for granting a new trial because, in part, it was impeachment evidence. The Court of Appeals also concluded that the evidence did not warrant a new trial because if it were admitted on retrial, there was no reasonable chance of a different result. Upon review, the Supreme Court held that impeachment evidence may be grounds for a new trial if it satisfies the four-part test set forth in "Michigan v. Cress." Furthermore, the Court held that a material, exculpatory connection must exist between the newly discovered evidence and significantly important evidence presented at trial. It may be of a general character and need not contradict specific testimony at trial. Also, the evidence must make a different result probable on retrial. Accordingly, the Court vacated the Court of Appeals' judgment and remanded this case to the trial court for determination of whether the newly discovered evidence satisfies "Cress." View "Michigan v. Grissom" on Justia Law

The Supreme Court granted leave in two cases to address the question whether a person injured while driving a motor vehicle that the person had taken contrary to the express prohibition of the owner may avail himself or herself of personal protection insurance benefits (PIP benefits) under the no-fault act, notwithstanding the fact that MCL 500.3113(a) bars a person from receiving PIP benefits for injuries suffered while using a vehicle that he or she "had taken unlawfully, unless the person reasonably believed that he or she was entitled to take and use the vehicle." Upon review, the Supreme Court held that any person who takes a vehicle contrary to a provision of the Michigan Penal Code (including MCL 750.413 and MCL 750.414, the "joyriding" statutes) has taken the vehicle unlawfully for purposes of MCL 500.3113(a). Furthermore, the Court held that the use of the phrase "a person" in MCL 500.3113(a) "clearly and plainly" includes a family member who has taken a vehicle unlawfully, thereby precludes that person from receiving PIP benefits. View "Progressive Marathon Ins. Co. v. Spectrum Health Hospitals" on Justia Law