People of Michigan v. Branquell Sayman-Anthony Bates

CourtMichigan Court of Appeals
DecidedFebruary 13, 2026
Docket371525
StatusUnpublished

This text of People of Michigan v. Branquell Sayman-Anthony Bates (People of Michigan v. Branquell Sayman-Anthony Bates) 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.

Bluebook
People of Michigan v. Branquell Sayman-Anthony Bates, (Mich. Ct. App. 2026).

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

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED February 13, 2026 Plaintiff-Appellee, 2:35 PM

v No. 371525 Ingham Circuit Court BRANQUELL SAYMAN-ANTHONY BATES, LC No. 29-000126-FC

Defendant-Appellant.

Before: GADOLA, C.J., and BOONSTRA and PATEL, JJ.

PER CURIAM.

Defendant appeals by right his jury-trial convictions of two counts of first-degree criminal sexual conduct (CSC-I), MCL 750.520b(1)(f) (use of force or coercion causing personal injury). Defendant was sentenced, as a second-offense habitual offender, MCL 769.10, to consecutive prison terms of 262 to 480 months (21¾ to 40 years) for each count. Finding no errors warranting reversal, we affirm.

I. BACKGROUND

Defendant and M M-H met in 2017 and frequently socialized with a mutual group of friends. On August 29, 2018, defendant forced himself on M M-H. M M-H struggled to get away from defendant. She told him no and repeatedly demanded that he stop. Defendant slapped, bit, and choked M M-H during the struggle. He threatened to punch her if she continued to fight. Defendant pinned M M-H’s legs up by her arms and put his mouth and tongue on her vagina. M M-H struggled against defendant and repeatedly told him to stop. He eventually did. But as M M-H was lying with her back facing defendant and crying, defendant violated her further by inserting his penis into her vagina. Once again, M M-H told defendant to stop multiple times. After several minutes, he finally stopped.

Several days later, M M-H reported the assault to the police. Following an investigation, defendant was charged with two counts of CSC-I. Defendant testified on his own behalf at trial. He maintained that he and M M-H engaged in consensual intercourse, but M M-H expressed regret after the fact because she was worried how it would affect their group of friends. Defendant denied

-1- slapping, biting, or strangling M M-H. Defendant was convicted and sentenced as described above. Defendant now appeals.

II. SPEEDY TRIAL

Defendant argues that his constitutional right to a speedy trial was violated, and he was prejudiced by the five-year delay from the time of his arrest to the time that trial began. We disagree.

This Court reviews for an abuse of discretion a trial court’s decision on a motion to dismiss. People v Witkoski, 341 Mich App 54, 59; 988 NW2d 790 (2022). “Whether a defendant was denied his constitutional right to a speedy trial is a mixed question of fact and law.” People v Jones, __ Mich App __, __; __ NW2d __ (2024) (Docket No. 365590); slip op at 3 (cleaned up). Constitutional questions are reviewed de novo and the trial court’s attributions of delay are reviewed for clear error. Id. “Clear error exists if the reviewing court is left with a definite and firm conviction that a mistake has been made.” People v Miller, 482 Mich 540, 544; 759 NW2d 850 (2008) (cleaned up).

In Jones, this Court explained a criminal defendant’s right to a speedy trial:

Both the United States and Michigan Constitutions guarantee the right in criminal prosecutions to a “speedy” trial. US Const, Am VI; Const 1963, art 1, § 20. “Whenever the defendant’s constitutional right to a speedy trial is violated, the defendant is entitled to dismissal of the charge with prejudice.” MCR 6.004(A). “The time for judging whether the right to a speedy trial has been violated runs from the date of the defendant’s arrest.” People v Williams, 475 Mich 245, 261; 716 NW2d 208 (2006). “[A] defendant’s right to a speedy trial is not violated after a fixed number of days.” Id. “In determining whether a defendant has been denied the right to a speedy trial, we balance the following four factors: (1) the length of delay, (2) the reason for delay, (3) the defendant’s assertion of the right, and (4) the prejudice to the defendant.” Id. at 261-262. [Jones, __ Mich App at __; slip op at 3.]

“These factors are often known as the Barker factors, as they were first announced by the United States Supreme Court in Barker v Wingo, 407 US 514, 530; 92 S Ct 2182; 33 L Ed 2d 101 (1972).” People v Smith, __ Mich App __, __; __ NW3d __ (2024) (Docket No. 362114); slip op at 3 n 1.

At the outset, we note that defendant’s arguments conflate the 180-day rule outlined in MCL 780.131(1) and defendant’s constitutional right to a speedy trial. “The 180-day rule is distinct from a criminal defendant’s constitutional right to a speedy trial under our federal and state Constitutions, US Const, Am VI; Const 1963, art 1, § 20[.]” People v Witkoski, 341 Mich App at 60. Because defendant’s statement of questions presented only addresses his speedy-trial right, any issue regarding the 180-day rule is waived. See People v Fonville, 291 Mich App 363, 383; 804 NW2d 878 (2011) (stating that an issue not contained in the statement of questions presented is waived on appeal); see also MCR 7.212(C)(5) (stating that an appellant’s brief must contain “[a] statement of questions involved, stating concisely and without repetition the questions involved in the appeal.”).

-2- A. LENGTH OF DELAY

The first Barker factor is undisputed. Defendant was arrested in December 2018 and arraigned in January 2019. Trial commenced nearly five years later in August 2023. “Following a delay of eighteen months or more, prejudice is presumed, and the burden shifts to the prosecution to show that there was no injury.” Williams, 475 Mich at 262. “Under the Barker test, a ‘presumptively prejudicial delay triggers an inquiry into the other factors to be considered in the balancing of the competing interests to determine whether a defendant has been deprived of the right to a speedy trial.” Id. (cleaned up).

B. REASON FOR DELAY

The second Barker factor is the reason for delay. “[C]ourts may consider which portions of the delay were attributable to each party when determining whether a defendant’s speedy trial rights have been violated and may attribute unexplained delays—or inexcusable delays caused by the court—to the prosecution.” People v Lown, 488 Mich 242, 261-262; 794 NW2d 9 (2011) (cleaned up). “Although delays inherent in the court system . . . are technically attributable to the prosecution, they are given a neutral tint and are assigned only minimal weight in determining whether a defendant was denied a speedy trial.” Smith, __ Mich App at __; slip op at 3 (cleaned up).

Defendant acknowledges that there is no evidence of bad faith but argues that all of the pretrial delays should be attributable to the prosecution because he did not “agree to, cause or request, a single delay” and delays inherent in the court system are “technically attributable to the prosecution.” Defendant claims that the pretrial and trial dates scheduled between May 6, 2019, and April 8, 2021 “all were adjourned without consent or stipulation from the defense.” The record does not support defendant’s argument.

On December 27, 2018, the criminal complaint was authorized, and a warrant was issued. Defendant was arraigned on the CSC charges in the district court on January 2, 2019. Following a preliminary examination, defendant was bound over to the circuit court on all counts. A jury trial was scheduled for May 6, 2019.

On the same date that the CSC warrant was issued, defendant was arrested in a separate case arising out of a December 25, 2018 incident.

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Related

Berger v. United States
295 U.S. 78 (Supreme Court, 1935)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Alabama v. Bozeman
533 U.S. 146 (Supreme Court, 2001)
People v. Kowalski
803 N.W.2d 200 (Michigan Supreme Court, 2011)
People v. Lown
794 N.W.2d 9 (Michigan Supreme Court, 2011)
People v. Tennyson
790 N.W.2d 354 (Michigan Supreme Court, 2010)
People v. Dupree
788 N.W.2d 399 (Michigan Supreme Court, 2010)
People v. Swafford
762 N.W.2d 902 (Michigan Supreme Court, 2009)
People v. Miller
759 N.W.2d 850 (Michigan Supreme Court, 2008)
People v. Williams
716 N.W.2d 208 (Michigan Supreme Court, 2006)
People v. Peterson
537 N.W.2d 857 (Michigan Supreme Court, 1995)
People v. Asevedo
551 N.W.2d 478 (Michigan Court of Appeals, 1996)
People v. Callon
662 N.W.2d 501 (Michigan Court of Appeals, 2003)
People v. Horn
755 N.W.2d 212 (Michigan Court of Appeals, 2008)
People v. Carines
597 N.W.2d 130 (Michigan Supreme Court, 1999)
People v. Sabin
620 N.W.2d 19 (Michigan Court of Appeals, 2000)
People v. Petrella
380 N.W.2d 11 (Michigan Supreme Court, 1986)
People v. Patton
775 N.W.2d 610 (Michigan Court of Appeals, 2009)
People v. Unger
749 N.W.2d 272 (Michigan Court of Appeals, 2008)

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People of Michigan v. Branquell Sayman-Anthony Bates, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-branquell-sayman-anthony-bates-michctapp-2026.