People of Michigan v. Chad Robert Bruining

Michigan Court of Appeals·Decided December 22, 2025·No. 367023·Unpublished

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED December 22, 2025

Plaintiff-Appellee, 8:52 AM

v No. 367023 Kent Circuit Court

CHAD ROBERT BRUINING, LC No. 21-005525-FC

Defendant-Appellant.

Before: M. J. KELLY, P.J., and REDFORD and FEENEY, JJ.

M. J. KELLY, P.J. (dissenting).

I respectfully dissent.

On the day of his trial, Chad Bruining was offered a plea deal by the prosecution. The record reflects that Bruining had many questions regarding the details of the plea bargain and its potential impact upon his future. The court, the prosecutor, and Bruining’s lawyers answered his questions and attempted to clarify aspects of the plea that repeatedly confused Bruining. Interspersed in the discussion of the plea offer, Bruining was repeatedly questioned regarding whether he desired to change from his jail-issued clothing into civilian clothing. Bruining, who was still cogitating on whether he should or should not accept the plea offer, did not satisfactorily answer the questions relating to his choice of attire.

The overlapping discussions lasted approximately 30 minutes, after which, the prosecutor stated:

Your Honor, I’m going to withdraw the plea in approximately five minutes.

We’ve been on the record here for 30 minutes, getting nothing accomplished. Mr. Bruining will have the next five minutes to make a decision, and if he hasn’t entered a plea by then, the People are withdrawing their agreement to 25 years, and we’ll just try the case.

Thereafter, Bruining conferred with his lawyers. One of his lawyers then stated that it “looks like we’re going to have to have a trial.” Bruining responded, “I didn’t say that.” His other lawyer then requested that the trial court ask Bruining “one more time” if he wanted to accept the plea

offer. Bruining stated that he understood that he needed to make a decision. The court agreed, noting that Bruining had “one minute before the offer’s not there anyway and the decision would be made for you.”

Bruining then stated multiple times that he “guessed” that his decision was “to take the plea agreement.” His lawyer then instructed him to “[s]top talking” and that they were “going to try it.” Bruining protested. He stated, unequivocally, “My decision was to take the plea deal.” When the court asked him to repeat it, he stated that he guessed that he was “taking the plea deal.” The court took his statements as an acceptance of the plea offer made by the prosecution by asking him to stand and raise his right hand. Notably, the prosecutor did not state at that time—or at any future time—that the plea had expired. Nor is there any indication on the record, after Bruining stated that he would accept the plea agreement, that the prosecutor otherwise exercised his right to withdraw the plea.

The record plainly reflects that Bruining was asked by the court and both of his lawyers to raise his right hand. He was not told that he needed to be sworn in so that the court could engage in a plea colloquy. When he expressed confusion as to what was “going on,” the deputy—not the court, his lawyers, or the prosecutor—advised that he needed to be sworn in. He was again asked to raise his right hand.1 He started to say something but was interrupted by his lawyer stating that “we’re going to have a trial.” The court then stated that time was “up anyway.” Bruining was then taken to change out of his jail garb despite the fact that he had never made a decision on that matter.

The majority reads the above exchange far differently than I. They stress the times that Bruining indicated that he “guessed” he would accept the plea, and brush aside his unequivocal statement that his decision was to take the plea agreement. They state that the agreement expired before the plea was accepted by the court and so the prosecutor implicitly withdrew it. In support, they cite People v Heiler, 79 Mich App 714, 722; 262 NW2d 890 (1977), for the proposition that, so long as the defendant is not prejudiced, a prosecutor may revoke a plea offer until the time that the trial court accepts the plea. I do not find Heiler dispositive, however.

In Heiler, the prosecutor withdrew a plea offer the day before the plea was to be entered.

Id. at 716. In contrast, in this case, the prosecutor set a five-minute time limit for the offer. When—by the trial court’s calculation—approximately one minute remained on the offer, Bruining stated that his decision was to accept the plea agreement. As noted above, the court asked him to repeat himself, he stated that he guessed he was taking the plea. At that time, the trial court started the procedure for accepting the plea agreement. That is, consistent with MCR 6.302(A), the court took steps to place Bruining under oath, which is a mandatory first step in accepting a

1 Both the trial court and the majority rely heavily on Bruining’s failure to raise his right hand and be sworn after the court accepted his statement that “My decision was to take the plea deal.” Indeed, it was when and because his manacled hand was not sufficiently raised that the process collapsed. But Michigan law is clear: “Witnesses need not raise their right hands when taking an oath to testify truthfully, and such oaths need not be prefaced with any particular formal words.” People v Putnam, 309 Mich App 240, 244; 870 NW2d 593 (2015).

plea by a criminal defendant. Notably, the trial court did not find Bruining’s use of the word “guess” as an equivocation and instead found his proclamation that he would take the plea to be a genuine acceptance of the prosecutor’s offer within the time limit set for Bruining to accept the offer. Thus, on this record, I would hold that Bruining accepted the plea agreement within the five minute timeframe given by the prosecutor and the trial court signaled its willingness to accept that plea when it began the required colloquy under MCR 6.302. At that time, the five-minute timeframe was no longer applicable. Thus, withdrawal of the plea by expiration of the timeframe was no longer an option.

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Related

People v. Heiler
262 N.W.2d 890 (Michigan Court of Appeals, 1977)
People v. Putman
870 N.W.2d 593 (Michigan Court of Appeals, 2015)