Justia Michigan Supreme Court Opinion Summaries

A defendant was charged with multiple counts related to child abuse and torture after her six-year-old son was found with bruises, swelling, and scarring on his body during a police welfare check. Medical professionals observed signs consistent with nonaccidental injuries. The defendant admitted to tying her son’s wrists with a belt for hours at a time and acknowledged that her partner had also tied him up. At trial, the child testified that he was restrained with zip ties in the defendant’s presence. An expert in child abuse pediatrics diagnosed the child with “medical torture,” a clinical term describing exposure to repeated physical assaults and psychological maltreatment. The expert clarified that her diagnosis was medical, not legal, and that she could not speak to the legal definition of “torture.”The Wayne Circuit Court conducted a jury trial, resulting in the defendant’s conviction for torture, second-degree child abuse, second-degree child abuse in the presence of another child, and third-degree child abuse. The jury acquitted her of one count involving another child. The Michigan Court of Appeals affirmed the convictions but vacated the sentences due to a scoring error and remanded for resentencing. The appellate court rejected the argument that the expert’s testimony about “medical torture” was improper, finding it distinguished from testimony that would address legal responsibility or intent.The Michigan Supreme Court reviewed whether the expert’s testimony diagnosing “medical torture” impermissibly invaded the jury’s role. The Court held that the testimony was inadmissible because it was unhelpful to the jury, lacked a reliable foundation, and encroached on the jury’s determination of guilt. However, the Court concluded the error did not affect the outcome of the proceedings, given the substantial evidence properly admitted. The Supreme Court affirmed the judgment of the Court of Appeals. View "People of Michigan v. Alexander" on Justia Law

The defendant was arrested in connection with a fatal shooting and, following his arrest, was given Miranda warnings. Police initially did not interrogate him because they believed he was intoxicated. The next day, during a videorecorded interrogation, the defendant waived his rights but later invoked his right to counsel, stating he needed appointed counsel. Police then left, purportedly to locate an attorney, but after more than two hours returned and informed the defendant that no attorney was available and he did not have the money to hire one. The defendant expressed confusion and asked clarifying questions. Police indicated that unless the defendant agreed to speak without an attorney, they could not discuss the case further. The defendant ultimately agreed to speak without counsel, was given Miranda warnings again, and made incriminating statements.The Wayne Circuit Court, after reviewing the interrogation video, granted the defendant’s motion to suppress the statements. The court found that police communications had frustrated the required Miranda advice by suggesting that the defendant’s right to counsel depended on his ability to pay, thereby undermining his rights. The trial court also found that police had reinitiated interrogation after the defendant invoked his right to counsel.The Michigan Court of Appeals reversed the suppression order, holding that the defendant’s waiver was voluntary, knowing, and intelligent, and that police had not violated his constitutional rights. The defendant sought further review.The Michigan Supreme Court held that the defendant’s Fifth Amendment rights under Miranda were violated. The Court found that police undermined the required advice of rights by suggesting that the right to counsel depended on the defendant’s ability to pay and that the prosecution failed to show the defendant reinitiated the interrogation. The Court reversed the Court of Appeals’ judgment and remanded for further proceedings, ordering suppression of the defendant’s post-invocation statements. View "People Of Michigan v. Fenderson" on Justia Law

The case involved a defendant who, at age 18, ingested a large amount of LSD with a friend, AC, at her home. After taking the drug, the defendant removed his pants and underwear, made statements suggesting sexual intent, and groped AC. AC resisted and escaped, seeking help from her mother. The defendant then exhibited erratic behavior, fled into the night naked from the waist down, and was later found by police, who described him as hallucinating and confused. He was taken to a hospital, where, about an hour after being found, he was read his Miranda rights by a sheriff’s deputy. The defendant then made an incriminating statement, “I am a rapist and I am fucked,” during the ensuing interrogation.The Grand Traverse Circuit Court denied the defendant’s motion to suppress the statement, concluding he had made a valid waiver of his Miranda rights. After a jury trial, the defendant was convicted of assault with intent to commit criminal sexual conduct involving penetration. His motions for a new trial or an evidentiary hearing on ineffective assistance of counsel were denied. The Michigan Court of Appeals affirmed the conviction, finding any error in admitting the statement harmless because the victim’s testimony was sufficient for conviction.The Michigan Supreme Court reviewed the case and held that the defendant’s Miranda waiver was not knowing and intelligent, considering the totality of the circumstances, including his age, lack of law enforcement experience, exhaustion, and ongoing effects of LSD. The Court further held that the erroneous admission of the defendant’s statement was not harmless beyond a reasonable doubt, as it was highly prejudicial evidence of intent. The Supreme Court reversed the judgment of the Court of Appeals, vacated the conviction, and remanded for further proceedings. View "People Of Michigan v. Soriano" on Justia Law

A commercial truck driver was injured in an accident while operating a tractor-trailer in Missouri. The tractor was registered in Michigan and titled to a limited liability company (LLC) solely owned by the plaintiff, while the trailer was owned by a different LLC. Under a lease agreement, the plaintiff’s LLC leased the tractor to the other LLC, and the plaintiff exclusively operated the tractor. Insurance coverage for the tractor was provided by a policy that excluded personal protection insurance (PIP) when the vehicle was used to transport cargo, and the other LLC’s insurance did not cover PIP for the tractor. The plaintiff, who lived with his parents in Michigan, was not a named insured on his father’s auto policy, nor was the tractor listed as a covered vehicle.After the accident, the plaintiff sued several insurers, arguing that one of them should provide PIP benefits under Michigan’s no-fault act. The Wayne Circuit Court denied summary disposition to one insurer and dismissed others from the case. On appeal, the Michigan Court of Appeals affirmed, finding insufficient evidence to classify the plaintiff as the tractor’s owner or registrant. It ruled that the plaintiff’s claim for PIP benefits was not barred and that his father’s insurer was the highest priority insurer.The Michigan Supreme Court, in reviewing the case, held that the plaintiff was an “owner” of the tractor under MCL 500.3101(3)(l)(i) because he had the right to use the vehicle in a manner consistent with ownership for more than 30 days. The Court found that his exclusive, regular use and control of the tractor, as the sole member and agent of the LLC, satisfied the statutory definition of ownership. Because he failed to maintain the required insurance, the plaintiff was excluded from recovering PIP benefits under MCL 500.3113. The Supreme Court reversed the Court of Appeals and remanded the case to the trial court. View "Abdulla v. Progressive Southeastern Insurance Company" on Justia Law

The case arose from a dispute over property ownership following the death of a homeowner who did not leave a will. The defendant, who had lived in the home with his children and grandmother, refused to leave after her death despite an eviction order. When sheriff’s deputies arrived to enforce the eviction, the defendant resisted leaving and was arrested. As a result, he was charged with trespassing and two counts of resisting or obstructing a police officer. The defendant maintained throughout that he believed he had a right to remain in the home and thus was not trespassing.After a jury trial in Emmet Circuit Court, the defendant was convicted on all counts. He moved for a new trial, arguing that his Sixth Amendment rights were violated when his counsel conceded guilt on the trespassing charge during closing argument without consulting him or securing his consent. At the evidentiary hearing, trial counsel testified that the defendant had consistently maintained his innocence before trial and was not informed of the plan to concede guilt. The trial court denied the motion, reasoning that the defendant failed to cooperate with counsel and did not object to the concession. The Court of Appeals affirmed, finding that counsel acted within his discretion given the lack of communication.The Michigan Supreme Court reviewed the case and held that under McCoy v. Louisiana, a criminal defendant has the right to decide the objective of the defense, including maintaining innocence. The Court found that defense counsel’s unilateral concession of guilt, despite the defendant’s insistence on innocence and without consultation, violated this right. The Court clarified that a defendant is not required to contemporaneously object to preserve this claim. The structural error required automatic reversal. The judgment of the Court of Appeals was reversed, the convictions vacated, and the case remanded for a new trial on all charges. View "People Of Michigan v. Klungle" on Justia Law

A woman pleaded guilty to third-degree retail fraud after stealing clothing from a store and was sentenced in the 64B District Court to probation under the Holmes Youthful Trainee Act. As a condition of probation, she was prohibited from using or possessing marijuana, although the court provided no specific justification for this restriction. During probation, she tested positive for marijuana twice, leading to probation violation charges. She then moved to amend her probation to permit marijuana use consistent with the Michigan Regulation and Taxation of Marihuana Act (MRTMA) and to vacate or dismiss her probation violations, arguing that the MRTMA protected such use.The district court denied her motion, found her in violation, revoked her youthful trainee status, and sentenced her to jail. On appeal, the Montcalm Circuit Court stayed her jail sentence but otherwise affirmed the lower court's decisions. The Michigan Court of Appeals also affirmed, reasoning that the probation act prohibits probationers from violating federal law, and since federal law criminalizes recreational marijuana, the act allowed—if not required—courts to prohibit MRTMA-compliant marijuana use as a probation condition.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that a trial court may not prohibit MRTMA-compliant marijuana use as a probation condition solely because such use violates federal law. The Court explained that federal law does not preempt the MRTMA and that to the extent the probation act incorporates federal marijuana prohibitions, it is inconsistent with the MRTMA and does not apply to conduct permitted by the MRTMA. The Supreme Court remanded the case for the trial court to reconsider the defendant’s motions in light of this holding. View "People Of Michigan v. Hess" on Justia Law

A woman died from a pulmonary embolism roughly 30 days after undergoing knee replacement surgery. Her estate, through its personal representative, filed a medical malpractice suit in the Oakland Circuit Court against the operating surgeon, his orthopedic practice, and the hospital where the surgery occurred. The estate alleged that the surgeon negligently failed to prescribe a prescription-strength anticoagulant. The complaint was accompanied by an affidavit of merit from an orthopedic surgeon, attesting to his qualifications during the relevant time period. The estate timely identified this surgeon as its expert witness, but difficulty arose when he became unavailable for deposition. The estate attempted to substitute a new expert on its witness list without seeking court approval, prompting litigation over whether this substitution should be permitted.The Oakland Circuit Court struck the amended witness list and ordered the estate to produce the original expert for deposition. When the estate could not do so, it sought to amend its witness list and moved for voluntary dismissal, both of which the circuit court denied. The court found that the estate had not acted diligently, determined the affidavit of merit was invalid due to the expert’s lack of recent practice, and granted summary disposition in favor of the defendants, closing the case.The Michigan Court of Appeals held that the circuit court abused its discretion by considering only prejudice when denying the motion to amend the witness list and failing to apply the factors from Dean v Tucker. Upon review, the Michigan Supreme Court reversed in part, holding that the correct standard for amending a witness list is the “good-cause” standard of MCR 2.401(I)(2), not the Dean factors. The Supreme Court found that the circuit court abused its discretion under the good-cause standard and that summary disposition was prematurely granted. The case was remanded to the circuit court for further proceedings. View "Estate Of Harris v. Beaumont Health" on Justia Law

The case concerns a fatal collision between a car driven by the defendant and a motorcycle operated by the decedent. The incident occurred in Brighton Township, Michigan, when the decedent, after accelerating rapidly from a traffic light, struck the side of the defendant’s vehicle as the defendant attempted a U-turn. Eyewitness testimony suggested the decedent may have been speeding, potentially exceeding the speed limit by up to 20 miles per hour. Post-mortem toxicology indicated the decedent’s blood alcohol concentration (BAC) could have been between 0.071 and 0.081 g/dL at the time of the collision. The defendant sought to admit evidence of both the decedent’s speed and BAC as relevant to proximate cause and gross negligence.The 53rd District Court admitted evidence regarding the decedent’s speed but excluded the BAC evidence, deeming it irrelevant. The Livingston Circuit Court denied the defendant’s application for leave to appeal this exclusion. The Michigan Court of Appeals, in a split decision, affirmed the district court’s ruling, finding that People v Feezel required a preliminary showing of gross negligence before evidence of intoxication could be admitted and that no such showing was made in this case. The dissent argued for considering all conduct, including intoxication and speeding, together rather than in isolation.The Supreme Court of Michigan reviewed the case and reversed the Court of Appeals. The Court held that the district court abused its discretion by excluding the BAC evidence. Under People v Feezel, BAC evidence is relevant if it has any tendency to make gross negligence more or less probable. The Supreme Court found that, given the admissible evidence of speeding and acceleration, the BAC evidence was relevant to proximate causation and not unfairly prejudicial. The judgment of the Court of Appeals was reversed, the district court’s order vacated, and the case remanded for further proceedings. View "People Of Mi v. Morgan" on Justia Law

In this case, a homeowner experienced property damage when sewage backed up into his residence after a sewer line was damaged during nearby excavation work. The excavation was initiated by a utility company, which hired an excavator to install a new underground electrical line following a neighbor’s complaint about electrical service. Before the excavation, the excavator notified MISS DIG Systems as required by law, which then informed local facility owners, including the township. The township responded that it did not have any facilities in the area and did not mark any sewer lines. The homeowner alleged that the township failed to comply with its duty under the MISS DIG Underground Facility Damage Prevention and Safety Act by not marking a township-owned sewer line, leading to his damages.The Oakland Circuit Court denied the township’s motion for summary disposition, concluding that governmental immunity did not shield the township from liability because the MISS DIG Act created an exception. The court also granted the homeowner leave to amend his complaint to assert a claim under the sewage disposal system event (SDSE) exception to governmental immunity, and set aside the notice issue for further briefing. The Michigan Court of Appeals affirmed the trial court’s decision.Upon review, the Michigan Supreme Court held that a governmental agency cannot be held civilly liable for monetary damages for a violation of the MISS DIG Act in circuit court, as the statute provides that the exclusive remedy is to file a complaint with the Public Service Commission. The Court also found that the trial court erred in granting the homeowner leave to amend his complaint to assert the SDSE exception before he demonstrated compliance with the statutory notice requirement. The Supreme Court reversed the decisions of the lower courts on these issues, vacated the grant of leave to amend, and remanded for further proceedings. View "Zezula v. Brown" on Justia Law

A state agency responsible for Medicaid administration alleged that a pharmacy and its owner, operating as a Medicaid provider, received excess Medicaid payments between 2011 and 2016 by submitting claims for more medications than records supported. After an audit, an administrative law judge upheld the agency’s determination of overpayment. The agency issued a final order demanding repayment, which survived several unsuccessful challenges by the pharmacy. In 2022, the agency, represented by the Attorney General, filed a civil action in Ingham County seeking to enforce its order and alleging common-law and statutory conversion, breach of contract, and unjust enrichment related to the overpayments.The defendants moved to change venue, arguing that the action should be heard in Wayne County, where the pharmacy owner resided and where the acts giving rise to the claims allegedly occurred, based on Michigan’s tort venue statutes. The Ingham Circuit Court transferred the case to Oakland County, identifying it as the site of the original injury. The Michigan Court of Appeals affirmed, holding that the tort venue statutes took precedence over the Attorney General venue provisions and that venue was proper in Oakland County, where the pharmacy’s registered office was located and where the funds were allegedly wrongfully withheld.The Supreme Court of Michigan reviewed the case and agreed with the Court of Appeals that the tort venue statutes, specifically MCL 600.1629 as mandated by MCL 600.1641(2), governed the venue determination because the complaint contained multiple claims, including a tort. However, the Supreme Court held that the “original injury” occurred in Ingham County, where the state agency was deprived of the funds and conducts its business. Therefore, venue was proper in Ingham County, not Oakland County. The Court affirmed in part, reversed in part, and remanded for transfer of the case to the Ingham Circuit Court. View "Department Of Health And Human Services v. Nrk Rx Inc." on Justia Law