Justia Michigan Supreme Court Opinion Summaries

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 Isabella County Prosecuting Attorney filed a complaint for a temporary restraining order, a show-cause order, a preliminary injunction, and a permanent injunction, seeking to enjoin the operation of Compassionate Apothecary, LLC (CA), a medical-marijuana dispensary that was owned and operated by Brandon McQueen and Matthew Taylor. McQueen was a registered qualifying patient and a registered primary caregiver for three qualifying patients under the Michigan Medical Marijuana Act (MMMA). Taylor was the registered primary caregiver for two qualifying patients. They operated CA as a membership organization. The prosecuting attorney alleged that McQueen and Taylor’s operation of CA did not comply with the MMMA, was contrary to the Public Health Code (PHC), and, thus, was a public nuisance. The court denied the prosecuting attorney’s requests for a temporary restraining order, a show-cause order and injunction, concluding that the operation of CA was in compliance with the MMMA because the patient-to-patient transfers of marijuana that CA facilitated fell within the act’s definition of the “medical use” of marijuana. The prosecuting attorney appealed. The Court of Appeals reversed and remanded, concluding that defendants’ operation of CA was an enjoinable public nuisance because the operation of CA violated the PHC, which prohibits the possession and delivery of marijuana. Upon review, the Supreme Court concluded that the Court of Appeals reached the correct result because the act does not permit a registered qualifying patient to transfer marijuana for another registered qualifying patient’s medical use. Accordingly, the prosecuting attorney was entitled to injunctive relief to enjoin the operation of defendants’ business because it constituted a public nuisance. View "Michigan v. McQueen" on Justia Law

Plaintiff Cheryl Debano-Griffin sued Lake County and the Lake County Board of Commissioners alleging, in part, that she had been terminated from her position as the director of Lake County’s 911 department in violation of the Whistleblowers’ Protection Act (WPA) after she raised concerns about a potentially improper transfer of county funds from the county’s ambulance account and regarding the ambulance service provided to the county. Defendants moved to dismiss. The court denied the motion, and the jury returned a verdict in plaintiff’s favor. Defendants appealed. The Court of Appeals reversed and remanded for entry of an order granting summary judgment to defendants. In lieu of granting leave to appeal, the Supreme Court reversed the judgment of the Court of Appeals and remanded the case for consideration of an additional argument that had been raised by defendants. On remand, the Court of Appeals, held that plaintiff had failed to establish a genuine issue of material fact regarding the causation element of her claim and again reversed the trial court’s order denying defendants’ motion for summary judgment. Upon review of the matter, the Supreme Court concluded that plaintiff presented sufficient evidence that reasonable minds could differ regarding the board’s true motivation for eliminating her position and raised a genuine issue of material fact regarding causation. Defendants were not entitled to summary judgment. View "Debano-Griffin v. Lake County" 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

The issue before the Supreme Court in this case was the manner in which defendant JPMorgan Chase Bank, N.A. (Chase), the successor in interest to Washington Mutual Bank (WaMu), acquired plaintiffs' mortgage. Plaintiffs' mortgage was among the assets held by WaMu when it collapsed in 2008. Specifically, the issue was whether defendant acquired plaintiffs' mortgage by "operation of law" and, if so, whether MCL 600.3204(3), applied to the acquisition of a mortgage by operation of law. Upon review of briefs submitted by the parties and the applicable statutory authority, the Supreme Court held that defendant did not acquire plaintiffs' mortgage by operation of law. Rather, defendant acquired that mortgage through a voluntary purchase agreement. Accordingly, defendant was required to comply with the provisions of MCL 600.3204. Furthermore, the Court held that the foreclosure sale in this case was voidable rather than void ab initio. Accordingly, the Court affirmed in part and reversed in part the judgment of the Court of Appeals and remanded the case to the trial court for further proceedings. View "Kim v. J.P. Morgan Chase Bank, N.A." 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

Plaintiff Pamela Mattison, gave birth to twins who were conceived by artificial insemination after their father, Jeffery Mattison, had died. She sought social security survivors' benefits for the children based on Jeffery's earnings. The Social Security Administration denied her application, and an administrative law judge affirmed that decision. Plaintiff then filed an action in the United States District Court for the Western District of Michigan challenging the decision. That court has asked the Michigan Supreme Court to rule on whether the children could inherit from Jeffery under Michigan intestacy law. Having heard oral argument, the Supreme Court granted the district court's request to answer the question and held that under Michigan intestacy law, plaintiff's children could not inherit from Jeffery. The matter was returned to the district court for further proceedings. View "In re Mattison v. Social Security Comm." 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

Defendant-Appellee McKinley Hyten obtained a provisional driver's license in April 2004. In January 2007, Defendant's driver's license was suspended because of multiple moving violations and two minor traffic accidents. In light of what she perceived as assurances from her probation officer, Defendant anticipated that her license would be restored at a district court hearing scheduled for later that year. Defendant's mother Anne Johnson gave Defendant a vehicle, and given the anticipated restoration of the driver's license, sought to obtain automobile insurance for Defendant. Johnson telephoned an independent insurance agent who, after being told that the license had been suspended, informed Johnson that Defendant could not be insured until her license had been restored. Nonetheless, an application for insurance from Titan Insurance Company was filled out on Defendant's behalf, postdated to August 24, 2007. August 22, 2007, Defendant signed the application for insurance. At an August 24, 2007, hearing, Defendant's driver's license was not restored. Plaintiff-Appellee Titan Insurance Company was not informed of this fact. Subsequently, in February 2008, Defendant was driving the insured vehicle and collided with the vehicle of Howard and Martha Holmes, causing injuries to both. Titan then learned Defendant did not have a valid driver's license when the policy was issued. In anticipation that the Holmeses would be filing claims against Defendant for their injuries, Titan filed suit seeking a declaratory judgment. The trial court granted Defendant's motion for summary judgment. The Court of Appeals affirmed, asserting that once an insurable event occurred and a third party (the Holmeses) possessed a claim against the insured arising out of that event, the insurer was not entitled to reform the policy to avoid paying the third party. Titan appealed, and the Supreme Court reversed the Court of Appeals: in accordance with the Supreme Court's precedent in "Keys v Pace,"(99 NW2d 547 (1959)), the Court found "nothing in the law to warrant the establishment of an 'easily ascertainable' rule." The Court overruled "State Farm Mut Auto Ins Co v Kurylowicz," (242 NW2d 530 (1976)) and its progeny, and remanded the case for further proceedings.View "Titan Ins. Co. v. Hyten" on Justia Law