Justia Constitutional Law Opinion Summaries

Articles Posted in Michigan Supreme Court
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In case no. 157738, Demariol Boykin was convicted by a jury of first-degree murder and possession of a firearm during the commission of a felony (felony- firearm). He was initially sentenced to a mandatory term of life without the possibility of parole for first-degree murder, to be served consecutively to a two-year term for felony-firearm. Subsequently, the United States Supreme Court decided Miller v Alabama, 567 US 460 (2012), which held that sentencing an individual to mandatory life without the possibility of parole for a crime they committed before the age of 18 (a juvenile offender) violated the Eighth Amendment’s ban on cruel and unusual punishments and that trial courts are required to consider the attributes of youth when sentencing a juvenile offender to life without parole. In Montgomery v Louisiana, 577 US 190 (2016), the Supreme Court held that Miller was a substantive constitutional rule that was retroactive on state collateral review. The Michigan Legislature accounted for these changes by enacting MCL 769.25 and MCL 769.25a, which eliminated sentences of mandatory life imprisonment without the possibility of parole for all individuals who were convicted of specific crimes, including first-degree murder, for acts committed while they were juveniles. At resentencing, the prosecution did not move to seek a sentence of life without parole but instead sought a sentence of 40 to 60 years’ imprisonment, which the trial court imposed. Boykin appealed this sentence by right. In case no. 158695, Tyler Tate was convicted by a jury of first-degree premeditated murder, making a false report of a felony to police, and lying to a police officer in a criminal investigation. He was sentenced under MCL 769.25, which had already become law at the time of his sentence. As with Boykin, the prosecution did not move to seek a sentence of life without the possibility of parole but instead sought the imposition of a 40- to 60-year sentence, which the trial court imposed. The Michigan Supreme Court concluded that because it was unclear whether the trial courts properly considered youth to be mitigating in either of these consolidated cases, yet the Court of Appeals affirmed the trial courts’ sentencing decisions, the portions of both Court of Appeals opinions discussing defendants’ sentencing challenges were vacated and the cases were remanded to the Court of Appeals for further consideration. View "Michigan v. Boykin" on Justia Law

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Robert Taylor was convicted by jury of first degree felony murder, carjacking, conspiracy to commit carjacking, kidnapping conspiracy to commit kidnapping, and possession of a firearm during the commission of a felony. In 2009, defendant and his codefendant, Ihab Masalmani, abducted Matt Landry from outside a sandwich shop. Defendant acted as the lookout while Masalmani forced Landry into Landry’s car. The two then drove Landry away at gunpoint. Defendant and Masalmani held Landry against his will for several hours and stole money from his bank account during that time; Landry was later killed by a gunshot wound to the head. Defendant was sentenced to a mandatory term of life in prison without the possibility of parole (LWOP). The issue this case presented for the Michigan Supreme Court’s review provided an opportunity for the Court to provide “much-needed” guidance to criminal defendants, prosecutors, and trial courts on the proper procedure for conducting MCL 769.25 sentencing hearings when a prosecutor seeks to impose a sentence of life without parole (LWOP) for a crime committed when the defendant was a juvenile. The Court held that, as the moving party at a Miller hearing, the prosecutor bears the burden to rebut a presumption that LWOP is a disproportionate sentence under the clear and convincing standard. In this case, the trial court was not operating within the framework the Supreme Court set forth here. Defendant was therefore entitled to resentencing. Because the Court of Appeals failed to address a separate constitutional issue that could be dispositive, however, the Supreme Court remanded this case to the Court of Appeals to consider that issue in the first instance before any resentencing can take place. View "Michigan v. Taylor" on Justia Law

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Montez Stovall was convicted by jury for second-degree murder, a crime committed when he was a juvenile. Stovall argued that his sentence was cruel and/or unusual punishment under both the United States and Michigan Constitutions. Under current United States Supreme Court precedent, the Michigan Supreme Court concluded Stovall’s Eighth Amendment argument failed. However, the Court held his sentence of mandatory life without parole violated the Michigan Constitution’s ban on “cruel or unusual” punishment. Specifically, his sentence lacked proportionality because it failed to take into account the mitigating characteristics of youth, specifically late-adolescent brain development. Therefore, the Supreme Court reversed the portion of the judgment of the Court of Appeals affirming Stovall’s sentence, vacated Stovall’s life-without-parole sentence, and remanded this case to the Circuit Court for resentencing proceedings. View "Michigan v. Stovall" on Justia Law

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Kemo Parks was convicted by jury for first-degree premeditated-murder. Parks was 18 years old when he aided and abetted in the murder. Parks argued that his sentence was cruel and/or unusual punishment under both the United States and Michigan Constitutions. Under current United States Supreme Court precedent, the Michigan Supreme Court concluded Parks’s Eighth Amendment argument failed. However, the Court held his sentence of mandatory life without parole violated the Michigan Constitution’s ban on “cruel or unusual” punishment. Specifically, his sentence lacked proportionality because it failed to take into account the mitigating characteristics of youth, specifically late-adolescent brain development. Therefore, the Supreme Court reversed the portion of the judgment of the Court of Appeals affirming Parks’s sentence, vacated Parks’s life-without-parole sentence, and remanded this case to the Circuit Court for resentencing proceedings. View "Michigan v. Parks" on Justia Law

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Grant Bauserman, Karl Williams, and Teddy Broe, on behalf of themselves and all others similarly situated, brought a putative class action in the Michigan Court of Claims against the Unemployment Insurance Agency, alleging that the Agency violated their due-process rights, and that the Agency also engaged in unlawful collection practices. Plaintiffs, who were all recipients of unemployment compensation benefits, specifically alleged defendant had used an automated fraud-detection system, the Michigan Integrated Data Automated System (MiDAS), to determine that plaintiffs had received unemployment benefits for which they were not eligible and then garnished plaintiffs’ wages and tax refunds to recover the amount of the alleged overpayments, interest, and penalties that defendant had assessed without providing meaningful notice or an opportunity to be heard. Among other remedies for this constitutional violation, plaintiffs sought monetary damages. Although the Michigan Supreme Court had never specifically held that monetary damages were available to remedy constitutional torts, the Court now held that they were. “Inherent in the judiciary’s power is the ability to recognize remedies, including monetary damages, to compensate those aggrieved by the state, whether pursuant to an official policy or not, for violating the Michigan Constitution unless the Constitution has specifically delegated enforcement of the constitutional right at issue to the Legislature or the Legislature has enacted an adequate remedy for the constitutional violation. Because enforcement of Const 1963, art 1, § 17 has not been delegated to the Legislature and because no other adequate remedy exists to redress the alleged violations of plaintiffs’ rights, we agree that plaintiffs have alleged a cognizable constitutional-tort claim for which they may recover money damages and we agree with the lower courts that defendant was properly denied summary disposition.” View "Bauserman v. Unemployment Insurance Agency" on Justia Law

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In 2016, defendant James Beck was charged relating to allegations that he sexually assaulted his minor daughter, TG (first-degree criminal sexual conduct (CSC-I), and three counts of second-degree criminal sexual conduct (CSC-II)). During the jury’s deliberations, one of the jurors notified the trial court that another juror might have done outside research on the case. The trial court polled the jury by written note to find out whether any of the jurors were aware of that research. Two of the jurors responded affirmatively. The trial court rejected the parties’ requests to either replace the jurors or to allow them to remain seated, and determined that the entire jury was tainted and declared a mistrial. In 2017, while awaiting retrial, defendant was accused of sexually assaulting CS, the minor friend of one of his children, and was charged with two counts of CSC-I and one count of CSC-II. The 2016 charges and the 2017 charges were jointly tried in a second trial, and defendant was found guilty of all charges. The issues presented on appeal to the Michigan Supreme Court were: (1) whether the retrial of defendant’s original charges were barred by double jeopardy; (2) if barred, whether vacating those conviction would entitle defendant to any relief with respect to his remaining convictions; and (3) whether the trial court erred in imposing a mandatory sentence of 25 years for defendant’s CSC-I conviction when the information did not state the charge carried this minimum sentence. The Supreme Court found the trial court abused its discretion by declaring a mistrial without an inquiry sufficient to support a finding of manifest necessity, and vacated those convictions. The Court found defendant did not demonstrate he was entitled to any relief regarding the other convictions. Finally, the Court concluded the trial court committed plain error in imposing the mandatory 25-year minimum sentence because it was not charged, and defendant was not entitled to relief because this error did not result in a fundamentally unfair trial. View "Michigan v. Beck" on Justia Law

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David Lucynski was charged with operating a vehicle while intoxicated (OWI); driving with a suspended license; and operating a vehicle with an open container of alcohol in the vehicle. The officer in this case claimed that he followed defendant because he believed defendant committed a traffic violation that would have justified the subsequent seizure, questioning, search, and arrest. The district court held there was no traffic violation, that the seizure was unconstitutional, that defendant would not be bound over for operating while intoxicated (OWI), and that the unlawfully obtained evidence had to be suppressed. The prosecution argued that a “reasonable mistake” occurred as to the traffic violation, that suppression of the evidence was not required, and that the bindover decision was incorrect. The Court of Appeals agreed and further held that defendant had not been seized until after he made incriminating statements, and thus the district court erred. After its review, the Michigan Supreme Court held that defendant was seized under the Fourth Amendment when the officer blocked the driveway and defendant’s path of egress with a marked patrol car because, under the totality of the circumstances, a reasonable person would not have felt free to leave or to terminate the interaction. Second, the “impeding traffic” statute at issue, MCL 257.676b(1), is only violated if the normal flow of traffic is actually disrupted. Third, the officer’s mistaken reading of this unambiguous statute was not objectively reasonable, and thus no reasonable mistake of law occurred. Accordingly, the Supreme Court reversed the Court of Appeals and remanded this case to that court to determine whether application of the exclusionary rule was the appropriate remedy for the violation of defendant’s Fourth Amendment rights. View "Michigan v. Lucynski" on Justia Law

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This was the second time these consolidated cases went before the Michigan Supreme Court. Previously, the Court considered whether a decades-long procedure used by the Grand Rapids Police Department (the GRPD) was a policy or a custom attributable to the city of Grand Rapids (the City). At issue here was the constitutionality of the GRPD’s policy of photographing and fingerprinting individuals stopped without probable cause, referred to as the “photograph and print” (P&P) procedure. In considering the fingerprint component of the P&P procedure, the Court held that the P&P procedure was unconstitutional: "Fingerprinting an individual without probable cause, a warrant, or an applicable warrant exception violates an individual’s Fourth Amendment rights." View "Johnson v. Vanderkooi" on Justia Law

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Nancy Peeler (Docket No. 163667), Richard Baird (Docket No. 163672), and Nicolas Lyon (Docket No. 164191) were charged with various offenses for actions they took as state employees during the Flint water crisis. The cases did not proceed by the prosecutor issuing criminal complaints. Instead, at the request of the Attorney General’s office, the prosecutor proceeded under MCL 767.3 and MCL 767.4, which authorized the use of a “one-man grand jury.” Judge David Newblatt served as the one-man grand jury, considered the evidence behind closed doors, and then issued indictments against defendants; defendants’ cases were assigned to a circuit court judge. Peeler and Baird moved to remand their cases for a preliminary examination, but the court denied the motion, holding that indicted persons have no right to a preliminary examination. Peeler and Baird filed interlocutory applications for leave to appeal with the Court of Appeals, but the appellate court denied the motion. Lyon moved to dismiss the charges against him, arguing that he had a statutory right to a preliminary examination, that MCL 767.3 and MCL 767.4 did not confer the one-man grand jury with charging authority, and that those statutes violated the separation-of- powers doctrine and the right to due process. The circuit court denied the motion. Lyon sought an interlocutory application for leave to appeal that decision. Peeler and Baird sought leave to appeal the Court of Appeals’ denial of their applications to the Michigan Supreme Court, and Lyon sought leave to appeal the circuit court’s decision to the Michigan Supreme Court prior to a decision by the Court of Appeals. The Supreme Court concluded the circuit court erred by denying Peeler’s and Baird’s motions to remand for a preliminary examination. Further, while MCL 767.3 and MCL 767.4 authorized the use of a one-man grand jury to investigate, subpoena witnesses, and issue arrest warrants, those statutes did not authorize that one-man grand jury to issue an indictment initiating a criminal prosecution. The circuit court therefore also erred by denying Lyon’s motion to dismiss. View "Michigan v. Peeler" on Justia Law

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John Moss was convicted of third-degree criminal sexual conduct (CSC-III) after he pleaded no contest to the charge. The charge stemmed from allegations made by defendant’s adoptive sister. In exchange for his plea, the trial court dismissed the other charges that had been brought against defendant, including another count of CSC-III, and a fourth-offense habitual-offender enhancement. Defendant and the complainant did not have a birth parent in common, but they were both adopted by the same woman. After sentencing, defendant moved to withdraw his plea, arguing for the first time that he was not related to the complainant by either blood or affinity. The trial court denied the motion, determining that, although the adoptive siblings were not related by blood, they were related by affinity. Defendant sought leave to appeal to the Court of Appeals; the Court denied the application in an unpublished order. Defendant then sought leave to appeal to the Michigan Supreme Court. The Supreme Court remanded the case to the Court of Appeals to address whether a family relation that arises from a legal adoption was either effectively a blood relation, or a relation by affinity, as those terms were used in MCL 750.520b through MCL 750.520e. On remand, the Court of Appeals affirmed the trial court’s denial of defendant’s motion, reasoning that defendant and the complainant were effectively related by blood. With that finding, the appeals court considered it unnecessary to address whether defendant and the complainant were related by affinity, but it did so anyway because of the remand order and concluded that they were not related by affinity. Defendant again sought leave to appeal to the Supreme Court. The Supreme Court reversed, finding that defendant and the complainant, were adoptive siblings, and were not related by blood for purposes of the statute. "[T]he Court of Appeals erred by concluding otherwise." Because the order directing oral argument on the application only asked the parties to address whether defendant and the complainant were related by blood, the Court of Appeals’ conclusion that defendant and the complainant were not related by affinity was left undisturbed. Because an adequate factual basis for defendant’s plea did not exist in light of the Courts’ legal rulings, the case was remanded to the trial court for further proceedings. View "Michigan v. Moss" on Justia Law