20250121_C368226_41_368226.Opn.Pdf

CourtMichigan Court of Appeals
DecidedJanuary 21, 2025
Docket20250121
StatusUnpublished

This text of 20250121_C368226_41_368226.Opn.Pdf (20250121_C368226_41_368226.Opn.Pdf) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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20250121_C368226_41_368226.Opn.Pdf, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

In re BENJAMIN JAMES LUCAS.

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED January 21, 2025 Petitioner-Appellee, 1:31 PM

V No. 368226 Hillsdale Circuit Court Family Division BENJAMIN JAMES LUCAS, LC No. 2022-465354-DL

Respondent-Appellant.

Before: BOONSTRA, P.J., and K. F. KELLY and YOUNG, JJ.

PER CURIAM.

Respondent appeals by right the January 27, 2023 order of the family division of the circuit court (family division) waiving jurisdiction over respondent and transferring his case to the court of general jurisdiction. We vacate the order and remand for further proceedings.

I. PERTINENT FACTS AND PROCEDURAL HISTORY

On November 16, 2022, petitioner filed a delinquency petition against respondent, alleging one count of second-degree criminal sexual conduct (CSC-II). See MCL 750.520(c)(1)(a) and 750.520(c)(2)(b). Specifically, petitioner alleged that respondent, while 17 years of age, had sexual contact with a minor under the age of 13. At the preliminary hearing in the family division, respondent, who was 22 years old at the time, appeared without an attorney. The case was adjourned to allow counsel to be appointed for respondent.

On January 12, 2023 petitioner filed a motion for the family division to waive jurisdiction over respondent. That same day, the family division referee continued the preliminary hearing; respondent was represented by an attorney, and his mother was also present. Respondent’s attorney questioned the family division’s jurisdiction to hear the case, asserting that the case should have been filed in a court of general jurisdiction from the beginning because, at the time that

-1- respondent allegedly committed the offense, a 17-year-old person was legally considered an adult, and therefore a waiver hearing was not necessary. Petitioner responded that, because 18 years of age was now considered the age of majority, and because respondent was 17 years of age when he committed the offense, he was legally a juvenile at the relevant time, and therefore his case was properly initiated as a juvenile proceeding. Respondent entered a plea of not guilty to the CSC-II charge.

The hearing on petitioner’s motion for waiver took place on January 27, 2023 before a judge in the family division. On the same day, petitioner refiled in the family division the November 16, 2022 petition charging respondent, reflecting the original date-stamp, and also refiled the January 12, 2023 motion for waiver, also with its original date-stamp. At the beginning of the hearing, the judge expressed concern over a “change in the law,” and stated that she did “not believe that the change in the law made the present provisions of the law retroactive.” The judge noted that respondent was 17 at the time he allegedly committed the offense, which was the age of majority at that time, and questioned whether the family division had jurisdiction over respondent at all. Petitioner argued that the family division must look at the time that the offense was charged, not the time the offense was committed, and opined that the new law changing the age of majority to 18 “actually did apply retroactively,” given that “any cases [with a defendant under 18] that were pending in district court” when the law changed were “booted to juvenile court” for a waiver-of-jurisdiction hearing. Petitioner argued that this Court’s decision in In re Seay, 335 Mich App 715, 721; 967 NW2d 883 (2021), involved the same issue as the present case, and established that the family division had limited jurisdiction over respondent for the purpose of holding a hearing to determine whether jurisdiction should be waived and respondent’s case transferred to a court of general jurisdiction to proceed as an adult criminal case. Petitioner opined that, if the family division decided not to waive jurisdiction, the matter would not proceed at all, because “we can’t proceed in juvenile court and because the court’s failed to waive it over we can’t proceed in adult court.”

Respondent’s counsel agreed to proceed with a waiver-of-jurisdiction hearing, stating that “because of the way that the law is written now when the offense is actually charged versus when the offense [was] committed . . . [respondent] does have the right to the waiver proceeding.” Respondent’s counsel then waived the probable-cause portion of the hearing and focused on arguing the best interests of the juvenile and the public in moving the case to a court of general jurisdiction. The family division judge made certain that respondent understood what a probable- cause hearing was, and was agreeing to waive it knowingly and voluntarily, emphasizing that if respondent waived the probable-cause portion, “there will be no preliminary examination in district court if the court waives jurisdiction” pursuant to MCR 3.950(D)(1)(c)(ii). Both parties agreed to immediately move to the best-interest portion of the waiver hearing pursuant to MCR 3.950(D)(2).

Petitioner explained that, in this case, a 12-year-old child had “disclosed some inappropriate touching by an individual” to a child-advocacy center, but knew only this individual’s first name and where he lived, and that upon further investigation respondent ultimately “did admit that [it] had happened” to the investigating officer. Petitioner acknowledged that the charge was based on a one-time incident when respondent was 17 years old, and that respondent had no previous involvement with the juvenile-justice system. However, petitioner stated that the charge was a “very serious” one, that there was “very strong culpability” on

-2- respondent’s part, and that conviction as an adult carried a sentence of “up to 15 years in prison.” Also, according to petitioner, if respondent’s case remained in the family division, it would have to be dismissed. because respondent was currently too old to participate in any of the programming or dispositional options available to juveniles, and there was no remedy available in the juvenile system for him. Petitioner therefore argued that it was in the public interest to waive respondent’s case to a court of general jurisdiction.

Respondent’s attorney argued that the case concerned a single instance of misconduct that had occurred approximately five years earlier, and that because no other allegations had since been brought against respondent, and that no weapons, force or coercion were alleged to have been used, there was no indication that the public needed protection from him. Respondent also testified that he had no record of juvenile delinquency, that he had a “good” school record and “strong family support,” that he believed that he was on the autism spectrum, and that he was receiving counseling through sources outside of the juvenile system because the petition against him was not filed until he had aged out of the juvenile-counseling support system. Finally, respondent’s attorney indicated that respondent would participate in any service that the family division judge recommended.

The judge gave “credit” to respondent for having “no prior record of delinquency,” and for demonstrating his “willingness to participate meaningfully in an available program.” However, she found that the age gap between respondent and his alleged victim was “incredibly significant.” She further found that there was no evidence that respondent was autistic, and that the alleged offense was serious, as was respondent’s culpability in the matter.

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