Justia Criminal Law Opinion Summaries

A 16-year-old defendant shot and killed a 17-year-old in what appeared to be a gang-related incident. The defendant, riding in the backseat of a car, observed the victim wearing a rival gang’s T-shirt, exited the vehicle, and shot the victim five times. Charged with first-degree murder and felony-firearm, the jury convicted him of the lesser included offense of second-degree murder and felony-firearm. The trial court sentenced him as an adult to 50 to 75 years’ imprisonment for second-degree murder, consecutive to two years for felony-firearm, exceeding the advisory sentencing guidelines recommending 12 to 25 years or parolable life.On direct appeal, the Michigan Court of Appeals affirmed the conviction and sentence, finding no disproportionality under People v Milbourn. The Michigan Supreme Court denied leave to appeal. Decades later, the defendant filed a motion for relief from judgment, arguing his sentence was unconstitutional and disproportionate in light of Miller v Alabama and related cases. The Wayne Circuit Court denied the motion, as did the Court of Appeals. The Supreme Court remanded for reconsideration in light of People v Stovall and People v Boykin, which addressed youth sentencing.The Michigan Supreme Court held that a sentence of 50 to 75 years’ imprisonment for second-degree murder committed by a youthful offender violates the prohibition on cruel or unusual punishment under the state constitution and applies retroactively to cases on collateral review. The Court found that all Bullock factors supported this conclusion, noting that such a sentence is harsher than those imposed for first-degree murder on youths and fails to advance rehabilitation. The Court affirmed the Court of Appeals’ reversal of the trial court’s denial of relief, vacated the sentence, and remanded for resentencing, while vacating portions of the Court of Appeals’ opinion addressing Milbourn and Boykin. View "People Of Michigan v. Eads" on Justia Law

A man responded to an online advertisement posted by undercover law enforcement officers as part of a sting operation targeting child sex trafficking. The ad depicted an adult woman and described sexual activities. During a text exchange, the decoy stated that she was 15 years old. The defendant replied that the person needed to be at least 16, but after further discussion and a phone call (which was not recorded), the conversation resumed and the decoy again referenced sex for money. The defendant ultimately went to a hotel room where he was arrested and charged with several offenses, including accosting a child for immoral purposes and child sexually abusive activity.In the Van Buren Circuit Court, the defendant moved to dismiss the charges based on entrapment. The court held an evidentiary hearing and applied Michigan’s two-prong entrapment test, ultimately finding the defendant had not established entrapment under either prong and denied the motion. The defendant filed an interlocutory appeal in the Michigan Court of Appeals. While that appeal was pending, he pleaded guilty to accosting a child for immoral purposes in exchange for dismissal of the other charges. The Court of Appeals affirmed the trial court’s decision.The Michigan Supreme Court reviewed the case to clarify the standards for reviewing entrapment determinations and the legal framework for entrapment claims. The Court held that a trial court’s factual findings following an entrapment hearing are reviewed for clear error, but its ultimate legal determination regarding entrapment is reviewed de novo. The Court also clarified Michigan’s two-prong modified objective entrapment test, including the roles of unlawful inducement, reprehensible conduct, and escalation. The Court found that the lower courts did not properly consider whether law enforcement escalated the defendant’s conduct from a lesser crime to a more serious offense and remanded the case to the trial court for further proceedings. The Court of Appeals’ opinion was vacated. View "People Of Michigan v. Jade" on Justia Law

A 19-year-old defendant was charged with open murder, assault with intent to commit murder, and two counts of felony-firearm after allegedly shooting two companions while riding through a park, resulting in one fatality and serious injuries to the other individual. The defendant requested evaluations for competency and criminal responsibility. Medical experts concluded that, although the defendant suffered from a significant mental illness—diagnosed as schizophreniform disorder—he was competent to stand trial and was not legally insane at the time of the offense. Defense experts agreed he was not legally insane but argued that his mental illness affected his ability to form specific intent.The defendant sought to introduce evidence and jury instructions on diminished capacity, contending that his mental illness negated the specific intent required for the charged offenses. The Ottawa Circuit Court denied this request, relying on the Michigan Supreme Court’s prior decision in People v Carpenter, which held that evidence of mental incapacity short of insanity could not be used to negate specific intent. The defendant’s application for leave to appeal was denied by the Michigan Court of Appeals. He then sought interlocutory review in the Michigan Supreme Court, arguing that Carpenter was wrongly decided and should be overruled.The Michigan Supreme Court held that its decision in Carpenter was erroneous and overruled it. The Court concluded that Michigan’s legal-insanity statute does not bar defendants from presenting evidence of diminished capacity to challenge the mens rea of specific-intent crimes. The Court emphasized that diminished capacity and the insanity defense are distinct; the former may negate an element of a crime, while the latter is an affirmative defense. The Supreme Court therefore vacated the trial court’s order and remanded for further proceedings consistent with its opinion. View "People Of Michigan v. Madison" on Justia Law

A man was arrested without a warrant after taking his three-month-old daughter to the hospital, where doctors suspected abuse. He denied harming the child during initial police questioning. The child died that evening, and an autopsy the next day concluded her death was a homicide due to traumatic brain injury. Two days after his arrest, and at least 64 hours into his warrantless detention, the man waived his Miranda rights and made statements to a detective that included several explanations for his daughter’s injuries, including that he shook her. A magistrate later found probable cause and authorized a criminal complaint.The man was convicted by a jury in the Ingham Circuit Court of felony murder and first-degree child abuse. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied leave to appeal. Years later, the trial court granted the man’s motion for relief from judgment due to ineffective assistance of counsel, leading to a new trial. Before the retrial, the prosecution sought to admit his statements from the prolonged detention. The trial court, following a hearing, ruled the statements were voluntary under the factors from People v Cipriano and thus admissible, despite acknowledging that the man had been detained in violation of the Fourth Amendment under Riverside Co v McLaughlin. The Michigan Court of Appeals denied leave to appeal this ruling.The Michigan Supreme Court held that when an arrestee is detained in violation of the Fourth Amendment’s requirement for a prompt judicial determination of probable cause, any statements made must be excluded unless the prosecution proves the statements were sufficiently attenuated from the unconstitutional detention. Voluntariness under Cipriano is a separate inquiry. The Supreme Court vacated the trial court’s order admitting the statements and remanded for determination under the proper standard. View "People v. Sanders" on Justia Law

A 19-year-old defendant was charged with multiple offenses, including producing, distributing, and possessing child sexually abusive material, after police found images and incriminating communications on his cell phone during investigations related to a prior stalking complaint involving a 17-year-old. The defendant initially retained counsel, but due to communication breakdowns, both his retained and later court-appointed attorneys were permitted to withdraw. As a result, the defendant was left either entirely without counsel or with only advisory counsel during key pretrial proceedings, including a hearing on a motion to suppress evidence obtained from his phone and a motion to dismiss. The trial court did not ensure that the defendant knowingly and intelligently waived his right to counsel, nor did it adequately advise him of the consequences of self-representation.After a jury trial at which the defendant was ultimately represented again by counsel, he was convicted on all charges. The Michigan Court of Appeals affirmed the convictions, holding that although the trial court failed to comply with required procedures for waiver of counsel, the defendant was not entitled to relief because he had not been deprived of counsel at a critical stage, and any error did not warrant automatic reversal. The court also suggested the defendant might have forfeited his right to counsel through his conduct.The Michigan Supreme Court reviewed the case and held that the defendant was deprived of counsel during a critical stage of the proceedings, specifically at the suppression hearing addressing evidence central to the prosecution. The Court found no valid waiver of counsel, nor that the defendant had forfeited his right through misconduct. The Court determined that the deprivation constituted structural error, requiring automatic reversal. The judgment of the Court of Appeals was reversed, the convictions and sentences were vacated, and the case was remanded to the trial court for a new trial. View "People v. Haupt" on Justia Law

An elderly woman was found dead in her home after suffering multiple blunt force traumas to her head. The crime scene showed extensive blood, but no evidence directly linked any suspect. Several witnesses reported seeing the defendant in the neighborhood around the time of the murder; he had previously performed housework and yardwork for the victim. When questioned, the defendant denied involvement. He was arrested on November 29, 2017, though there was ambiguity regarding whether the arrest was for an unrelated 2016 misdemeanor or suspicion of homicide. The day after his arrest, the detective collected the defendant’s pants and other belongings from jail custody without seeking a warrant or consent. Over a month later, police submitted the pants for DNA testing, which revealed a small bloodstain matching the victim’s DNA.At the defendant’s first jury trial in the Genesee Circuit Court, the jury could not reach a verdict. At the retrial, the defense argued the tiny bloodstain did not connect the defendant to the violent crime scene and did not move to suppress the DNA evidence. The jury convicted the defendant of first-degree murder, and he was sentenced to life without parole. The defendant moved for a new trial or an evidentiary hearing, arguing the DNA evidence should have been excluded as the product of an unconstitutional search and that his counsel was ineffective for not seeking its suppression. The trial court denied the motion. The Michigan Court of Appeals affirmed, finding no constitutional violation and concluding counsel’s performance was reasonable.The Michigan Supreme Court reversed. It held that DNA testing of the defendant’s pants, performed without a warrant or consent, constituted an unreasonable search under Article 1, Section 11 of the Michigan Constitution. The court found that neither the inventory-search nor search-incident-to-arrest exceptions applied, especially since the arrest was for an unrelated charge. The court further held that trial counsel was ineffective for failing to seek suppression of this evidence, and that the error prejudiced the defendant, as the DNA evidence was the only physical evidence linking him to the crime. The case was remanded for further proceedings. View "People v. Serges" on Justia Law

A defendant, who was 15 years old at the time of the offense, was convicted in 1988 of first-degree felony murder, armed robbery, and felony-firearm following a bench trial. He received a sentence of life without parole for the murder conviction. After the United States Supreme Court decided in *Miller v. Alabama* that mandatory life without parole sentences for juveniles are unconstitutional, and in *Montgomery v. Louisiana* that this rule applies retroactively, the prosecution moved to reimpose the defendant’s life without parole sentence under Michigan law. At his resentencing hearing, the defendant presented expert psychological evidence suggesting his capacity for rehabilitation, while the prosecution presented no witnesses. The trial court reimposed the life without parole sentence, stating the prosecution did not bear the burden of proof.The Michigan Court of Appeals later vacated the amended sentence after the Michigan Supreme Court held in *People v. Taylor* that the prosecution bears the burden of proof at such hearings. On remand, the prosecution requested that the defendant be compelled to undergo a psychological evaluation by its expert or, alternatively, that the defense’s psychological evidence be excluded. The trial court granted this request, and the Court of Appeals affirmed that decision.The Michigan Supreme Court held that if a defendant intends to introduce expert psychological evidence at a Miller resentencing hearing, the trial court may require the defendant to submit to a psychological examination by a prosecution expert, consistent with the constitutional right against self-incrimination. However, evidence from this compelled examination is admissible only as rebuttal and not during the prosecution's case-in-chief. The court also clarified that the second Miller hearing is a new proceeding and vacated any order incorporating the record from the prior hearing. The case was remanded to the trial court for proceedings consistent with these rulings. View "People v. Black" on Justia Law

The defendant was convicted by a jury of assault with intent to commit murder, carrying a dangerous weapon with unlawful intent, and third-degree fleeing and eluding. At sentencing, the trial court calculated his guidelines minimum sentence range as 270 to 450 months for the assault conviction and imposed a sentence of 360 to 600 months. The defendant moved to correct his sentence, arguing that Prior Record Variable 2 and Offense Variable 12 were scored incorrectly, which would lower his guidelines range. The prosecution agreed with some of the scoring errors, but the trial court declined to resolve the precise range, stating it would impose the same sentence regardless of the corrected guidelines.The Michigan Court of Appeals affirmed the defendant’s sentence, holding that resentencing was unnecessary because the trial court had clearly indicated it would have imposed the same sentence even with the corrected guideline scores. However, the Court of Appeals remanded for the presentence investigation report to be amended to reflect the correct guideline scoring and range. On remand, the parties stipulated to a corrected range of 171 to 285 months, and the trial court amended the report but did not resentence the defendant.The Michigan Supreme Court reviewed whether resentencing is required when a sentence is based on inaccurate guidelines scoring and falls outside the corrected range, even if the trial court would have imposed the same sentence. The Court held that a defendant is entitled to resentencing in such circumstances, reaffirming that reliance on an incorrect guidelines range requires resentencing, regardless of the trial court’s stated intentions. The Court of Appeals’ judgment was reversed in part, and the case was remanded for resentencing, requiring the trial court to rescore the guidelines and consider the correct range, while allowing the same sentence if found to be reasonable and proportionate. View "People of Michigan v. Armogeda" on Justia Law

In 1976, the defendant was convicted by a jury of first-degree felony murder for aiding and abetting an armed robbery in which another individual committed a fatal shooting at a grocery store. The defendant was not present during the actual shooting but had provided information about the store’s occupants to the principal. He was sentenced to life imprisonment without the possibility of parole. The trial court’s instructions to the jury did not require a finding of malice as later defined by Michigan law.On direct appeal, the Michigan Court of Appeals reversed the conviction due to improper jury instructions regarding the mens rea for felony murder. However, the Michigan Supreme Court reinstated the conviction after its decision in People v Aaron, which redefined malice for felony murder but applied only to trials in progress or later. The case returned to the Court of Appeals, which affirmed the conviction, and the Michigan Supreme Court denied further review.In 2020, the defendant filed for post-judgment relief, arguing that his sentence was unconstitutional because the jury did not make a finding of malice as required by Aaron, and that mandatory life without parole was cruel or unusual punishment. The trial court denied his motion, stating it was bound by precedent, and the Court of Appeals denied leave to appeal.The Michigan Supreme Court held that mandatory life without parole for pre-Aaron felony murder constitutes cruel or unusual punishment under the Michigan Constitution if the jury was not instructed on malice as defined by Aaron, unless the prosecution can prove beyond a reasonable doubt that a jury would have found malice based on the trial evidence. If the prosecution fails to meet this burden, the no-parole aspect of the sentence must be struck, making the defendant eligible for parole. The trial court’s order was vacated in part, and the case was remanded for further proceedings. View "People Of Michigan v. Langston" on Justia Law

A man was stopped by police while driving a car matching the description of a vehicle seen leaving the scene of a shooting. Police found a loaded handgun in the glovebox. During questioning, the driver admitted to being at the scene and driving the car, but when asked for a DNA sample to compare with the handgun, he refused and ended the interview. At trial, the prosecutor argued that the defendant’s decision to stop cooperating was evidence of a “guilty conscience,” displaying a board with that phrase to the jury and contrasting his actions with those of other occupants who continued their interviews.After closing arguments, the Macomb Circuit Court judge raised concerns that the prosecutor’s comments improperly used the defendant’s invocation of his right to silence against him. Defense counsel moved for a mistrial, which the court granted. The defendant argued that a retrial would violate double jeopardy, but the trial court denied this, finding no evidence that the prosecutor specifically intended to provoke a mistrial. At the second trial, the prosecution shifted its theory, and the defendant was convicted. The Michigan Court of Appeals affirmed, holding that retrial was not barred under the standard from Oregon v Kennedy, 456 US 667 (1982), because the prosecutor’s misconduct was not intended to goad the defense into requesting a mistrial but was instead reckless or negligent.On further appeal, the Michigan Supreme Court held that the Kennedy standard does not properly protect the double-jeopardy rights guaranteed by the Michigan Constitution. The Court rejected Kennedy and adopted the broader standard from Pool v Superior Court, 139 Ariz 98 (1984), holding that retrial is barred if a mistrial is granted due to intentional, prejudicial prosecutorial misconduct pursued for an improper purpose with indifference to the risk of mistrial, and the resulting prejudice cannot be cured short of a mistrial. The Court vacated the judgment of the Court of Appeals and remanded for application of the new standard. View "People Of Michigan v. Jennings" on Justia Law