Justia Criminal Law Opinion Summaries

In 2005, the defendant's infant daughter, Nakita, died while under the defendant's care. The defendant claimed Nakita was choking, but after an autopsy, the medical examiner concluded that Nakita died from shaken baby syndrome (SBS). The defendant was convicted of first-degree felony murder in 2006 and sentenced to life in prison without parole. In 2017, the defendant filed a motion for relief from judgment, presenting new expert testimony that challenged the SBS diagnosis and suggested alternative causes of death, such as choking.The Wayne Circuit Court held an evidentiary hearing but ultimately denied the defendant's motion, ruling that the new expert testimony was inadmissible under Michigan Rule of Evidence (MRE) 702. The Michigan Court of Appeals affirmed this decision, agreeing that the biomechanical engineering evidence was inadmissible and that the new evidence did not make a different result probable on retrial.The Michigan Supreme Court reviewed the case and found that the trial court abused its discretion by excluding the expert testimony. The Court held that the biomechanical engineering evidence was relevant and reliable under MRE 702, as it was based on sufficient facts and reliable principles. The Court also determined that the new evidence, including the changed opinion of the original medical examiner and other expert testimony, made a different result probable on retrial. The Court concluded that the defendant had demonstrated "good cause" and "actual prejudice" as required by Michigan Court Rule (MCR) 6.508(D)(3) and satisfied all four prongs of the test established in People v. Cress.The Michigan Supreme Court reversed the lower courts' decisions and remanded the case for a new trial, allowing the new expert testimony to be considered. View "People Of Michigan v. Lemons" on Justia Law

Stephanie Wilson was driving a 2006 Saturn Ion with Malcolm Smith as a passenger when they were pulled over by a police officer surveilling a house for narcotics activity. The officer observed what he believed to be a hand-to-hand drug transaction involving Smith. After stopping the vehicle for a traffic violation, the officer found five empty syringes but no drugs. Wilson denied the officer's claim that she admitted to driving Smith to purchase drugs. The vehicle was seized, and nearly four months later, forfeiture proceedings were initiated.The Wayne Circuit Court granted summary disposition in favor of Wilson, finding that the officer's observation of a hand-to-hand transaction did not necessarily involve drugs. The court did not specify the grounds for its ruling. The plaintiff's motions for reconsideration and relief from judgment were denied. The Michigan Court of Appeals reversed the trial court's decision, holding that a reasonable fact-finder could conclude that Wilson used her vehicle to facilitate a drug purchase, making it subject to forfeiture.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that under MCL 333.7521(1)(d), a vehicle is subject to forfeiture only if it is used to transport illicit property for the purpose of its sale or receipt. The Court found that the elements of the statute were not concurrently fulfilled in this case. Specifically, while Wilson's vehicle was used to drive to a location where drugs were purchased, there was no evidence that the vehicle was used to transport drugs for the purpose of sale or receipt. Therefore, the vehicle was not subject to forfeiture under the statute. The Wayne Circuit Court’s grant of summary disposition in favor of Wilson was reinstated. View "In Re Forfeiture Of 2006 Saturn Ion" on Justia Law

Stephen M. Butka was accused of groping his two stepdaughters and masturbating in front of them when they were between 13 and 16 years old. He pleaded no contest to one count of third-degree child abuse in exchange for the dismissal of more severe charges. In 2006, he was sentenced to nine months in jail, two years of probation, and required to register as a sex offender. After successfully completing probation in 2008, Butka applied to have his conviction set aside in 2012, 2019, and 2021, but each application was denied, primarily due to the victims' objections.The Otsego Circuit Court denied Butka's applications, citing the ongoing emotional impact on the victims as inconsistent with the public welfare. The Court of Appeals affirmed this decision, relying on the precedent set in People v. Boulding, which required balancing the applicant's circumstances and behavior against the public welfare. The appellate court concluded that the victims' ongoing distress justified denying the application.The Michigan Supreme Court reviewed the case and clarified the interpretation of "public welfare" under MCL 780.621d(13). The Court held that the public welfare cannot be determined solely by the impact on the victims or a limited class of people. The Court found that the lower courts erred by focusing only on the victims' statements and not considering the broader public welfare. The Supreme Court reversed the Court of Appeals' judgment and the trial court's decision, directing the trial court to grant Butka's application to set aside his conviction. View "People v. Butka" on Justia Law

The defendant was convicted by a jury in the Allegan Circuit Court of multiple counts of criminal sexual conduct. During the trial, the presiding judge exchanged emails with the county prosecutor, expressing concerns about the police investigation. The defendant later discovered these communications and moved for a new trial, alleging judicial and prosecutorial misconduct, and ineffective assistance of counsel. The case was reassigned to a different judge, who granted the motion for a new trial due to the appearance of impropriety created by the emails. The prosecution appealed this decision.The Michigan Court of Appeals reversed the trial court's decision, holding that the trial court had abused its discretion in granting a new trial. The appellate court concluded that the trial judge's ex parte communications were permissible for administrative purposes under the judicial conduct code and did not influence the jury's verdict. The defendant then sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court reviewed the case and held that the trial judge's ex parte communications violated the Michigan Code of Judicial Conduct. The court found that these communications were not for administrative purposes and created an appearance of impropriety. However, the court concluded that the communications did not show actual bias or a high probability of bias that would violate the defendant's constitutional rights. The court also determined that the trial judge's failure to recuse herself did not result in a miscarriage of justice, as the jury was unaware of the communications and the trial prosecutor did not alter her strategy in response to them. Therefore, the court affirmed the Court of Appeals' decision, holding that the trial court had no legal basis to grant a new trial. View "People of Michigan v. Loew" on Justia Law

Dwight T. Samuels and his identical twin brother, Duane, were involved in a fight at a restaurant, leading to multiple felony charges against both. The prosecution offered a package-deal plea, requiring both brothers to plead guilty to certain charges in exchange for the dismissal of others. Initially, Dwight objected to the plea but changed his mind after learning his brother wished to accept it. Both brothers pleaded guilty, and the trial court accepted their pleas without raising the issue of voluntariness. At sentencing, they moved to withdraw their pleas, arguing the package-deal format was coercive. The trial court denied the motions without an evidentiary hearing, finding the pleas voluntary.The Michigan Court of Appeals denied Dwight's application for leave to appeal. The Michigan Supreme Court remanded the case to the Court of Appeals to consider whether an evidentiary hearing was required to determine the voluntariness of the plea. On remand, the Court of Appeals affirmed the trial court's decision, holding that the voluntariness of a plea induced by a promise of leniency to a relative is determined by whether the prosecution had probable cause to prosecute the third party.The Michigan Supreme Court reviewed the case and held that when a defendant's plea is made under a package-deal plea offer, and the record raises a question of fact about its voluntariness, a trial court must hold an evidentiary hearing. The court must consider the totality of the circumstances, guided by factors from In re Ibarra, to determine if the plea was voluntary. The Supreme Court found that the record raised a factual question about Dwight's plea and remanded the case to the trial court for an evidentiary hearing to assess the voluntariness of his plea. The Court of Appeals' judgment was reversed. View "People Of Michigan v. Samuels" on Justia Law

Damon E. Warner was charged with first- and second-degree criminal sexual conduct for allegedly assaulting his minor stepdaughter. During the investigation, Warner underwent three police interrogations, during which he initially denied the accusations but eventually signed a confession written by the police. A jury found him guilty of second-degree criminal sexual conduct but could not reach a verdict on the first-degree charge. Warner was sentenced to 10 to 30 years in prison. The first-degree charge was later dismissed without prejudice. Warner successfully appealed his conviction, and the Court of Appeals granted him a new trial.The Eaton Circuit Court allowed the prosecutor to reinstate the first-degree charge. Warner requested funds to hire an expert on false confessions and access to the victim’s medical and psychological records, but the trial court denied both motions. At the second trial, Warner was found guilty of first-degree criminal sexual conduct and sentenced to 20 to 40 years in prison. The Court of Appeals upheld the trial court's decision, stating that although the trial court misinterpreted the precedent set by People v Kowalski, it did not abuse its discretion in denying Warner's request for an expert witness.The Michigan Supreme Court reviewed the case and held that it was fundamentally unfair to deny an indigent defendant funding for an expert on false confessions when the veracity of the confession was central to the trial. The Court found that Warner had demonstrated a reasonable probability that the expert would aid his defense and that the absence of such an expert resulted in a fundamentally unfair trial. The Court of Appeals judgment was reversed, and the case was remanded for further proceedings. View "People v. Warner" on Justia Law

In 1993, William E. Neilly was convicted of first-degree felony murder, felon in possession of a firearm during the commission of a felony, and conspiracy to commit armed robbery. He was sentenced to life imprisonment without parole. However, subsequent rulings by the United States Supreme Court deemed mandatory life without parole sentences for defendants who committed crimes when under the age of 18 years old as unconstitutional. As a result, Neilly was resentenced to 35 to 60 years in prison. The trial court also ordered Neilly to pay $14,895.78 in restitution to the victim’s family for funeral expenses.Neilly appealed the restitution order, arguing that it violated the Ex Post Facto Clauses of the United States and Michigan Constitutions. He contended that the trial court ordered restitution under the current restitution statutes rather than the former restitution statutes in effect when he was originally sentenced in 1993. The Court of Appeals rejected Neilly’s argument, reasoning that restitution is a civil remedy and not punishment, and its imposition did not result in an increase in punishment in violation of the Ex Post Facto Clauses.The Michigan Supreme Court affirmed the lower court's decision. The court held that restitution imposed under the current statutes is a civil remedy, not a criminal punishment. Therefore, applying the restitution statutes to defendants whose criminal acts predate the enactment of the restitution statutes does not violate the Ex Post Facto Clauses of the United States and Michigan Constitutions. The court concluded that the trial court’s restitution order was affirmed. View "People v. Neilly" on Justia Law

John M. Burkman and Jacob A. Wohl were charged with bribing or intimidating voters, conspiracy to bribe or intimidate voters, and two counts of using a computer to commit a crime. The charges stemmed from a robocall they designed and financed in 2020, which targeted voters in Michigan areas with significant Black populations. The robocall claimed that voting by mail would result in the voter’s personal information becoming part of a public database used by the police to track down old warrants, by credit card companies to collect debt, and potentially by the Centers for Disease Control and Prevention to track people for mandatory vaccines. The district court found probable cause to believe that the defendants had committed the charged offenses and bound them over for trial. The defendants moved to quash the bindovers, arguing that the robocall was not a “menace” or “other corrupt means or device” under the relevant statute and that the statute was unconstitutional. The circuit court denied the motions.The Michigan Supreme Court held that the Court of Appeals erred in determining that the defendants’ conduct fell within the term “menace” as used in the relevant statute. However, the Court of Appeals correctly concluded that the defendants’ conduct fell within the statutory catchall term “other corrupt means or device.” The Supreme Court also held that the defendants’ conduct was not excluded from constitutional free-speech protections under the true-threat exception, but erred by holding that the defendants’ conduct was excluded from constitutional free-speech protections under the speech-integral-to-criminal-conduct exception. The Supreme Court adopted a limiting construction of the statute’s catchall provision and remanded the case to the Court of Appeals for further proceedings. View "People v. Burkman" on Justia Law

In 2012, Ronald Scott was arrested and charged with various crimes. After a jury trial, he was convicted of two counts of first-degree criminal sexual conduct and acquitted of other charges. Before trial, the prosecution sought to admit certain other-acts evidence, which the trial court ruled inadmissible. The prosecution appealed this decision, and the Court of Appeals reversed and remanded the case. Scott's trial began while his application for leave to appeal was still pending, and the other-acts evidence was admitted at trial. Scott was convicted and sentenced, and he appealed his convictions and sentences.The Court of Appeals vacated Scott's convictions and sentences, ruling that the trial court lacked subject-matter jurisdiction to conduct the trial under a precedent case, People v Washington. The Supreme Court later vacated this decision and remanded the case for reconsideration. On remand, the Court of Appeals held that resentencing a defendant whose application for leave was pending was not a structural error but a procedural error. The Court of Appeals then affirmed Scott's convictions but remanded the case for resentencing. Scott sought leave to appeal in the Supreme Court.The Supreme Court held that a trial court's failure to adhere to court rules staying a proceeding while an interlocutory appeal is pending is a procedural error, and any such error can be remedied through subsequent appellate review after a final judgment is entered. Interlocutory appeals do not divest a trial court of subject-matter jurisdiction over a case. The Supreme Court reversed the judgment and remanded the case to the Court of Appeals to assess whether the prosecution presented evidence at Scott's trial that violated the rules of evidence and, if so, whether Scott is entitled to a new trial. View "People Of Michigan v. Scott" on Justia Law

Joshua L-J Stewart was convicted by jury on three counts of armed robbery; assault with intent to commit murder; receiving and concealing stolen property valued between $1,000 and $20,000; and possession of a firearm during the commission of a felony. Defendant allegedly aided and abetted two other individuals in two armed robberies by serving as the getaway driver. Two of the victims were shot by the perpetrators during the robberies, and one of the victims died as a result of his injuries. Defendant was arrested and questioned after he drove one of the perpetrators to the hospital in the vehicle used in the robberies. Before trial, defendant moved to suppress statements he made during his police interview, arguing that the statements were involuntary because of coercive interview techniques and promises of leniency by the interrogating officers. The Michigan Supreme Court reversed the trial court's denial of defendant's motion to suppress evidence given in the police interview. The totality of the circumstances of defendant’s interrogation, including his age, the timing of the interview, the officers’ references to leniency, the officers’ use of falsehoods, and the officers’ overall tone and use of language, created an environment in which defendant’s free will was overborne and the statements he gave were involuntary. "The use of these statements at trial violated defendant’s constitutional rights, and he was entitled to a new trial." View "Michigan v. Stewart" on Justia Law