Justia Michigan Supreme Court Opinion Summaries

Defendant Glenn Williams appealed his conviction of armed robbery, arguing that because he was unsuccessful in feloniously taking or removing any actual property from the intended target of his robbery, there was not a sufficient factual basis to support his guilty plea to the charge of armed robbery. Upon review, the Supreme Court disagreed: "[w]hen the Legislature revised the robbery statute, MCL 750.530, to encompass a 'course of conduct' theory of robbery, it specifically included 'an attempt to commit the larceny' as sufficient to sustain a conviction for robbery itself. [The Court] conclude[d] that this amendment effectuated a substantive change in the law governing robbery in Michigan such that a completed larceny is no longer necessary to sustain a conviction for the crime of robbery or armed robbery." View "Michigan v. Williams" on Justia Law

The Supreme Court granted the prosecution’s application for leave to appeal to resolve whether Michigan law recognizes the doctrine of "imperfect self-defense" as an independent theory that automatically mitigates criminal liability for a homicide from murder to voluntary manslaughter when a defendant acts as the initial aggressor and then claims that the victim’s response necessitated the use of force. The Court held that the doctrine does not exist in Michigan law as a freestanding defense mitigating murder to voluntary manslaughter, although the Court recognized that factual circumstances that have been characterized as imperfect self-defense may negate the malice element of second-degree murder. When analyzing the elements of manslaughter in light of defendant’s self-defense claim, the Court concluded that the Court of Appeals erred in its ruling on the sufficiency of the prosecution’s evidence to sustain Defendant Verdell Reese, III's manslaughter conviction. Therefore, the Court reversed in part the Court of Appeals’ judgment, affirmed the trial court’s verdict of manslaughter, and remanded this case to the Court of Appeals for further consideration of Defendant’s remaining issue on appeal. View "Michigan v. Reese" on Justia Law

In combined cases, the Supreme Court examined the Indian Child Welfare Act (ICWA) to decide whether several issues relating to the Act's notice provision mandate notice be sent to the appropriate tribe or to the Secretary of the Interior. Because the question of whether notice violations occurred in these cases began with determining whether the tribal-notice requirement was triggered, the Court first considered what indicia of Indian heritage sufficed to trigger the notice requirement. Further, the Court then considered whether a parent could waive the rights granted by ICWA to an Indian child's tribe and determine the appropriate recordkeeping requirements necessary to document the trial court's efforts to comply with ICWA's notice provision. "While it is impossible to articulate a precise rule that will encompass every possible factual situation, in light of the interests protected by ICWA, the potentially high costs of erroneously concluding that notice need not be sent, and the relatively low burden of erring in favor of requiring notice, we think the standard for triggering the notice requirement of 25 USC 1912(a) must be a cautionary one." Upon review, the Supreme Court held that: (1) sufficiently reliable information of virtually any criteria on which tribal membership might be based suffices to trigger the notice requirement; (2) a parent of an Indian child cannot waive the separate and independent ICWA rights of an Indian child's tribe and that the trial court must maintain a documentary record; and (3) the proper remedy for an ICWA-notice violation is to conditionally reverse the trial court and remand for resolution of the ICWA-notice issue. View "In re J.L. Gordon, Minor" on Justia Law

In combined cases, the Supreme Court examined the Indian Child Welfare Act (ICWA) to decide whether several issues relating to the Act's notice provision mandate notice be sent to the appropriate tribe or to the Secretary of the Interior. Because the question of whether notice violations occurred in these cases began with determining whether the tribal-notice requirement was triggered, the Court first considered what indicia of Indian heritage sufficed to trigger the notice requirement. Further, the Court then considered whether a parent could waive the rights granted by ICWA to an Indian child's tribe and determine the appropriate recordkeeping requirements necessary to document the trial court's efforts to comply with ICWA's notice provision. "While it is impossible to articulate a precise rule that will encompass every possible factual situation, in light of the interests protected by ICWA, the potentially high costs of erroneously concluding that notice need not be sent, and the relatively low burden of erring in favor of requiring notice, we think the standard for triggering the notice requirement of 25 USC 1912(a) must be a cautionary one." Upon review, the Supreme Court held that: (1) sufficiently reliable information of virtually any criteria on which tribal membership might be based suffices to trigger the notice requirement; (2) a parent of an Indian child cannot waive the separate and independent ICWA rights of an Indian child's tribe and that the trial court must maintain a documentary record; and (3) the proper remedy for an ICWA-notice violation is to conditionally reverse the trial court and remand for resolution of the ICWA-notice issue. View "In re C.I. Morris, Minor" on Justia Law

The issue before the Supreme Court was whether the Double Jeopardy Clauses of the Michigan and federal constitutions barred defendant's retrial. Defendant Lamar Evans was accused of burning a vacant house. There was no dispute that the trial court wrongly added an extraneous element to the statute under which Defendant was charged. Specifically, the trial court ruled that the prosecution was required to present proof that the burned house was not a dwelling, which was not a required element of MCL 750.73. As a result of the trial court's erroneous addition of this extraneous element to the charged offense, it granted Defendant's motion for a directed verdict and entered an order of acquittal, dismissing the case. Upon review, the Supreme Court held that when a trial court grants a defendant's motion for a directed verdict on the basis of an error of law that did not resolve any factual element of the charged offense, the trial court's ruling does not constitute an acquittal for the purposes of double jeopardy and retrial is therefore not barred. Accordingly, because the trial court's actions did not constitute an acquittal for the purposes of double jeopardy, the Court affirmed the judgment of the Court of Appeals and remanded the case for further proceedings. View "Michigan v. Evans" on Justia Law

The issue before the Supreme Court was whether the ineffective assistance of Defendant Richard Armstrong's trial counsel by failing to introduce evidence of cell phone records that would have undermined the complainant's credibility prejudiced Defendant, entitling him to a new trial. The Court of appeals held that Defendant failed to show any resulting prejudice. Upon review of the trial court record, the Supreme Court disagreed with the Court of Appeals and held that Defendant's counsel's performance was ineffective and prejudiced Defendant. Accordingly, the Court reversed the Court of Appeals and remanded the case for further proceedings. View "Michigan v. Armstrong" on Justia Law

Defendant Donald Richardson and his wife had a "poor relationship" with some of their neighbors which resulted in several altercations. One such altercation escalated and Defendant was charged with two counts of assault with intent to commit murder, two counts of assault with intent to do great bodily harm less than murder, two counts of felonious assault and one count of felony-firearm. At trial on these charges, Defendant asserted a theory of self-defense. At the close of trial, the court read a pattern jury instruction, which permitted consideration of whether Defendant had a duty to retreat. After a day of deliberations, the jury asked the judge to define "home." The court explained that an individual had no duty to retreat before using deadly force if in his own home or curtilage of that dwelling. Two days later, the jurors could not make a decision. The court reread the instruction that lies at the heart of this case, but did not reiterate the definition of curtilage. On appeal to the Supreme Court, Defendant argued that the court's use of the jury instruction, and its omission to reread the definition of curtilage (which is not part of the pattern jury instruction) was in error. Upon review of the trial record, the Supreme Court held that it was appropriate for the trial court to use the standard jury instruction in this case. Further, the Court found there was adequate evidence from which the jury could conclude that Defendant did not need to use deadly force to defend himself. Rather than grant leave to appeal, the Court affirmed Defendant's convictions for assault. View "Michigan v. Richardson" on Justia Law

Defendant Charles Fackelman was found guilty but mentally ill of home invasion, felonious assault, and felony-firearm charges that resulted from an altercation he had with a man Defendant believed caused the death of his teenage son in an episode of "road rage." Defendant perceived the man to have been unremorseful about his role in the tragedy and antagonistic toward Defendant and his family during subsequent legal proceedings. The issue at Defendant's trial was whether he was legally insane at the time of the incident. The prosecution's expert opined that he was not, while Defendant's expert opined that he was. These experts were the only doctors who testified at trial but were not the only expert opinions before the jury. The jury was repeatedly told about a third expert diagnosis whose report was reviewed by the other experts, but was "conspicuously absent" from trial. This third expert's report was never admitted into evidence for the jury's review. Upon review of the trial record and the briefs submitted by the parties, the Supreme Court concluded that use of the "tie breaking" diagnosis as substantive evidence of Defendant's sanity compromised his constitutional right to be confronted with the witnesses against him. The Court reversed the judgment of the lower courts, vacated Defendant's convictions, and remanded the case for further proceedings. View "Michigan v. Fackelman" on Justia Law

At issue before the Supreme Court was whether Defendant Edward Kowalski's convictions of accosting a minor to commit an immoral act and using a computer as means to accomplish that act should have been overturned because of an error in jury instructions. The Court of Appeals ruled that the convictions should be overturned. The instructions given at trial did not properly instruct the jury on the actus reus of the applicable statute, and as such were given in error. Upon review of the trial record and the applicable legal authority, the Supreme Court concluded that regardless of whether Defendant waived review of the jury instructions, they were not an "outcome-determinative" error. Sufficient evidence was presented at trial to support the jury's verdict. The Court reversed the appellate court and reinstated Defendant's convictions. View "Michigan v. Kowalski" on Justia Law

In this case, the Supreme Court was asked to determine whether the "community caretaking" exception to the Fourth Amendment's requirement that a warrant be obtained before entering a residence applied to a first-responder answering a 911 call. Defendant Mark Slaughter resided in a townhouse. His neighbor saw water running down her basement wall and over her electrical box. After a few failed attempts to reach Defendant, the neighbor called 911. The city dispatched several firefighters to the townhouse. After consulting with the neighbor, the firefighters entered Defendant's residence. When the firefighter went to the basement to shut off the water, he observed in plain view, grow lights and several dozen marijuana plants. The firefighter reported what he saw to the local police. Defendant was charged with manufacturing with the intent to deliver the marijuana. He filed a pretrial motion to suppress evidence of the plants, grow lights, and everything else police officers confiscated, arguing that the firefighter's entry into his townhouse violated his Fourth Amendment rights. The circuit court granted the motion, holding that the firefighter did not attempt to verify the existence of running water in the wall prior to entering Defendant's home. The Court of Appeals affirmed in a split decision, the majority holding that a "community caretaking" exception to the Fourth Amendment could apply to searches by firefighters only when they were investigating a possible fire hazard. Upon review, the Supreme Court overturned the lower courts' decisions, holding that the community caretaking exception applies to firefighters "no less than to police officers" when they are responding to emergencies that threaten life or property. Furthermore, the Court concluded that the firefighter's actions in this case were reasonable, thus satisfying the community caretaking exception to the warrant requirement. The Court remanded the case back to the circuit court for further proceedings. View "Michigan v. Slaughter" on Justia Law