Justia Michigan Supreme Court Opinion Summaries

A prisoner was observed by a corrections officer receiving a crumpled piece of paper from another inmate. The officer demanded the prisoner hand over the paper, which contained two orange strips later identified as Suboxone, a controlled substance. The prisoner did not have a prescription for Suboxone. Initially, the prisoner tested positive for Suboxone, but a retest was negative. The prisoner was charged with being a prisoner in possession of a controlled substance (PPCS).The 85th District Court bound the prisoner over for trial, concluding there was sufficient evidence for probable cause without ruling on whether PPCS required a mens rea element. The Manistee Circuit Court denied the prisoner's motion to include a mens rea element in the jury instructions, relying on a previous case, People v Ramsdell, which held PPCS to be a strict-liability offense. The Court of Appeals affirmed the conviction, agreeing that PPCS is a strict-liability crime.The Michigan Supreme Court reviewed the case to determine if PPCS is a strict-liability offense or if it requires a mens rea element. The Court held that MCL 800.281(4) does not plainly impose strict liability and that MCL 8.9(3) applies, requiring the prosecution to prove that the defendant acted with intent, knowledge, or recklessness. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with this opinion. View "People v. Tadgerson" on Justia Law

Carl T. Masi was charged with multiple counts of first-degree and second-degree criminal sexual conduct involving three minors, AU, SU, and MU, who alleged that Masi began sexually assaulting them when they started living with him. Masi sought to introduce evidence related to the complainants' sexual histories, specifically that AU had viewed pornography during prior sexual abuse by her uncle. The trial court denied Masi's motion, ruling that this evidence was inadmissible under the rape-shield statute, MCL 750.520j, and People v Morse, because there was no conviction related to the prior abuse.The Michigan Court of Appeals affirmed the trial court's decision, holding that evidence of AU viewing pornography during prior sexual abuse was "sexual conduct" under the rape-shield statute and thus inadmissible under Morse. Masi then sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court reviewed the case and held that the plain meaning of "sexual conduct" in the rape-shield statute includes both voluntary and involuntary behavior, thus encompassing nonvolitional acts such as involuntarily viewing pornography during sexual abuse. The Court overruled Morse to the extent that it required a conviction for prior sexual conduct to be admissible. Instead, the Court established a new standard requiring an in camera evidentiary hearing to determine the admissibility of such evidence based on specific factors, including whether the prior act occurred, its similarity to the current allegations, its relevance, necessity to the defense, and whether its probative value outweighs its prejudicial effect.The Michigan Supreme Court affirmed in part and vacated in part the lower courts' decisions and remanded the case to the Macomb Circuit Court to apply the new standard in an in camera hearing. View "People v. Masi" on Justia Law

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

Natalie C. Nelson was convicted of felonious assault, possession of a firearm during the commission of a felony, and domestic violence. The incident involved Nelson and her boyfriend, Aaron Lewis, at Nelson's home. Nelson discovered Lewis was in contact with a cousin she believed had engaged in child sexual abuse. An altercation ensued, with conflicting testimonies about who was the aggressor. Nelson claimed self-defense, stating Lewis threatened to kill her and physically assaulted her, prompting her to retrieve a firearm.The Wayne Circuit Court sustained the prosecution's hearsay objection when Nelson attempted to testify about Lewis's threat during direct examination. However, Nelson mentioned the threat during recross-examination. The jury was instructed to consider all evidence but not to consider stricken testimony. Nelson was convicted and sentenced to probation, imprisonment, and time served for the respective charges. On appeal, the prosecution conceded the hearsay objection was erroneous. The Michigan Court of Appeals affirmed the convictions, holding the error was not outcome-determinative since the threat was eventually introduced, and jurors are presumed to follow instructions.The Michigan Supreme Court reviewed the case, focusing on whether the trial court's error was outcome-determinative under People v. Lukity. The Court held that the error was outcome-determinative, as the threat was central to Nelson's self-defense theory, and the jury likely did not know whether to consider the once-excluded evidence. The Court reversed the Court of Appeals' judgment and remanded the case for a new trial, emphasizing that the trial court's error deprived Nelson of a meaningful opportunity to support her self-defense claim and likely confused the jury. View "People Of Michigan v. Nelson" on Justia Law

The defendant, a 16-year-old student, was charged with assault with intent to commit great bodily harm less than murder (AWIGBH) under an aiding and abetting theory. The incident involved two other students, TI and CB, who attacked the victim by hitting and kicking him. The defendant did not participate in the physical attack but recorded the incident on his cell phone and shared the video with other students. The prosecution argued that the defendant's recording of the attack encouraged the assailants. Instead of filing a juvenile petition, the prosecution sought to try the defendant as an adult under the automatic waiver statute, arguing that the shoes worn by the assailants were used as dangerous weapons.The 53rd District Court found probable cause to believe that the defendant had aided and abetted the assault and bound him over to the criminal division of the circuit court. The circuit court denied the defendant's motion to quash the bindover and dismiss the charges, concluding that a shoe could be used as a dangerous weapon. The Court of Appeals affirmed the circuit court's decision, with a dissenting opinion arguing that the shoes did not constitute dangerous weapons and that the defendant was not armed with a dangerous weapon.The Michigan Supreme Court reviewed the case and held that for the criminal division of the circuit court to have jurisdiction under the automatic waiver statute, the juvenile defendant must be armed with a dangerous weapon. The Court found no evidence that the defendant was armed with a dangerous weapon during the assault. Consequently, the statutory requirements for automatic waiver were not met, and the criminal division of the circuit court did not have jurisdiction over the defendant. The Court reversed the Court of Appeals' judgment in part, vacated it in part, and remanded the case to the circuit court to grant the defendant's motion to quash the bindover and transfer the case to the family division of the circuit court. View "People Of Michigan v. Oslund" on Justia Law

During an altercation at a party, the defendant pushed the victim in the chest, causing the victim's chest to bleed. Although no one saw the defendant with a knife, the victim's treating physicians concluded that the victim had been stabbed. The defendant was convicted by a jury of assault with intent to do great bodily harm (AWIGBH) and felonious assault.The Isabella Circuit Court sentenced the defendant to concurrent prison terms of 5 to 10 years for AWIGBH and 2 to 4 years for felonious assault. The defendant appealed, and the Michigan Court of Appeals vacated the felonious assault conviction, reasoning that convictions for both AWIGBH and felonious assault were inconsistent because the offenses are mutually exclusive. The prosecutor then applied for leave to appeal to the Michigan Supreme Court, which granted the application.The Michigan Supreme Court held that the defendant's convictions for both AWIGBH and felonious assault did not violate double-jeopardy protections because the AWIGBH statute authorizes multiple punishments for the same conduct. The court noted that the AWIGBH statute explicitly states that it does not prohibit a person from being charged with, convicted of, or punished for any other violation of law arising out of the same conduct. Therefore, the conflicting intent requirements of the two statutes did not render the convictions mutually exclusive. The court reversed the judgment of the Court of Appeals to the extent it addressed the mutually exclusive verdicts doctrine and reinstated the defendant's conviction of felonious assault. View "People of Michigan v. Mckewen" 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 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