Justia Michigan Supreme Court Opinion Summaries

Defendant Rayfield Clary was convicted by jury of assault with intent to commit murder and possession of a firearm during the commission of a felony. Defendant's first trial ended in mistrial; after his second, he appealed the outcome. The Court of Appeals affirmed in an unpublished opinion, concluding that defendant had been improperly impeached with his silence. The Supreme Court reversed, finding that the prosecution’s references at trial to defendant’s postarrest, post-Miranda silence with the police were improper. View "Michigan v. Clary" on Justia Law

Defendant David Burns was tried by jury and convicted of first-degree sexual conduct. The victim, his four-year-old daughter, told a bible school teacher, who happened to be a forensic interviewer and sexual-assault nurse examiner. The teacher conditionally testified at trial regarding the child's out-of-court statements before the child herself was called to testify. The prosecutor then tried to have the child testify, but was unsuccessful. The teacher's testimony was admitted, on the grounds that defendant told the child "not to tell" of the alleged abuse, rendering her unavailable to testify, and making the teacher's statement admissible under the forfeiture-by-wrongdoing rule. The Court of Appeals reversed, concluding that the State failed to establish by a preponderance defendant had both specific intent to cause the child's unavailability, and that the wrongdoing in fact caused her unavailability. The State appealed, but the Supreme Court agreed with the appellate court and affirmed that court's reversal. View "Michigan v. Burns" on Justia Law

Defendant Rodney Lee Koon was stopped for speeding. During the stop, defendant voluntarily produced a marijuana pipe and informed the arresting officer that he was a registered patient under the MMMA and was permitted to possess marijuana. A blood test to which defendant voluntarily submitted several hours later revealed that his blood had a THC content of 10 ng/ml. The State charged defendant with operating a motor vehicle with the presence of a schedule 1 controlled substance in his body under MCL 257.625(8). The prosecution sought a jury instruction that the presence of marijuana in defendant's system resulted in a per se violation of the Michigan Vehicle Code. Defendant argued that the zero-tolerance provision could not possibly apply to MMMA registered patients because the MMMA prevented the prosecution of registered patients for the medical use of marijuana, including internal possession, and only withdraws its protection when the patient drives while "under the influence" of marijuana. Moreover, the MMMA resolved conflicts between all other acts and the MMMA by exempting the medical use of marijuana from the application of any inconsistent act. The district court and circuit court agreed with defendant. The Court of Appeals reversed, reasoning that the MMMA yielded to the Legislature's determination in MCL 257.625(8) that it is unsafe for a person to drive with any marijuana in his or her system. The issue before the Supreme Court centered on whether the MMMA's protection superseded the Michigan Vehicle Code's prohibition and allowed a registered patient to drive when he or she has indications of marijuana in his or her system but is not otherwise under the influence of marijuana. The Court concluded that it did. Accordingly, the Court reversed the Court of Appeals, reinstated the judgment of the Circuit Court, and remanded this case to the District Court for further proceedings. View "Michigan v. Koon" on Justia Law

The issue before the Supreme Court in this case concerned whether defendant Kadeem White was subjected to "interrogation" or "express questioning or its functional equivalent" after he invoked his right to remain silent. Defendant allegedly turned a drug buy into an armed robbery by pulling out a gun instead of making the purchase. He and the victim allegedly struggled over the gun, the gun went off, and the victim was killed. Defendant was then taken into custody. Because the Court agreed with the Court of Appeals that defendant was not subjected to such questioning after he invoked his right to remain silent, the Supreme Court affirmed the judgment of the Court of Appeals, which correctly reversed the trial court's decision to suppress defendant's voluntarily given confession. View "Michigan v. White" on Justia Law

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

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