People of Michigan v. James Douglas Frisbie

CourtMichigan Court of Appeals
DecidedMay 23, 2025
Docket370286
StatusUnpublished

This text of People of Michigan v. James Douglas Frisbie (People of Michigan v. James Douglas Frisbie) 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. James Douglas Frisbie, (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

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED May 23, 2025 Plaintiff-Appellee, 10:20 AM

v No. 370286 Kent Circuit Court JAMES DOUGLAS FRISBIE, LC No. 21-008822-FH

Defendant-Appellant.

Before: N. P. HOOD, P.J., and BOONSTRA and FEENEY, JJ.

BOONSTRA, J. (dissenting).

I respectfully dissent. In my view, the trial court correctly denied defendant’s motion to suppress because the initial seizure of his cell phone was a valid warrantless seizure, and because defendant consented to the subsequent search of the phone. Additionally, the district court correctly bound defendant over for trial because the prosecution presented sufficient evidence that defendant had committed the crime of perjury during an investigative subpoena examination.

I. SEARCH AND SEIZURE

The majority concludes that the trial court erred by denying defendant’s motion to suppress evidence found on his cell phone. I disagree. Although the “search and seizure” of private property by the government is often treated as a single event, there are important differences between a search and a seizure. See People v Hughes, 506 Mich 512, 529-530; 958 NW2d 98. A seizure of property “occurs when there is some meaningful interference with an individual’s possessory interests in that property.” People v Serges, ___ Mich App ___; ___ NW3d ___ (2024) (Docket No. 355554), slip op at 6 (quotation marks and citations omitted). “A search occurs under the Fourth Amendment when the government violates the subjective expectation of privacy that society recognizes as reasonable.” Id. (quotation marks and citations omitted).

The majority holds that defendant’s consent to the search of his cell phone was coerced, and it therefore skips over any consideration of whether the initial seizure of defendant’s phone was a valid warrantless seizure. I conclude that the two must be analyzed separately, and I will accordingly first analyze the initial seizure of defendant’s phone and then the subsequent search.

-1- We review for clear error a trial court’s findings of fact at a suppression hearing, and we review de novo questions of constitutional law and the trial court’s ultimate decision on a motion to suppress. People v Woodard, 321 Mich App 377, 382-383; 909 NW2d 299 (2017).

A warrantless seizure, like a warrantless search, is per se unreasonable under the Fourth Amendment, unless an exception to the warrant requirement is present. People v Moorman, 331 Mich App 481, 485; 952 NW2d 597 (2020). The warrantless seizure of a defendant’s cell phone, regardless of consent, was squarely addressed by this Court’s recent decision in People v Evans, ___ Mich App ___; ___ NW3d ___ (2025) (Docket No. 371021). In Evans, this Court noted that an exception to the warrant requirement exists for seizures when, looking at the totality of the circumstances from the perspective of law enforcement, probable cause exists to believe that the property holds evidence of a crime and there is “more than a mere possibility that there is a risk of the immediate destruction or removal of evidence.” Id. at ___; slip op at 4. Regarding cell phones specifically, this Court observed that “courts at both the federal and state level have been fairly uniform in concluding that, when police have (1) probable cause to believe evidence of a crime is contained in a cell phone and (2) a legitimate concern that the information could be deleted from that cell phone, police act reasonably in seizing the phone pending the diligent seeking of a search warrant.” Id. at __, slip op at 5-6 (citations omitted). This Court then concluded that the seizure of the defendant’s cell phone in that case was reasonable under the totality of the circumstances:

[I]t is the combination (“totality of the circumstances”) of the ability to quickly delete evidence from these phones, the admitted evidence of a crime on the phone, defendant’s awareness of the potential crime and the police investigation, and his initial reluctance to turn it over, which together created a sufficient basis for Dole to reasonably believe that the evidence could be destroyed if the phone was not immediately seized pending obtainment of a search warrant. . . . Contrary to defendant’s argument, the prosecution was not required as a matter of law to present evidence showing defendant’s actual intent to delete information before Dole could seize the cell phone.” [Evans, ___ Mich App at ___; slip op at 7.]

As in Evans, defendant in this case contacted police and told them that he had information concerning a potential crime; defendant was thus aware of the potential crime and the police investigation. The investigative subpoena examination provided information from which law enforcement could conclude that evidence of the crime may have existed on defendant’s phone, inasmuch as defendant testified to making and receiving phone calls that might have involved the case and to having the same phone number since 1990.1 Defendant was also extremely reluctant to turn over his phone. Although there are some factual differences, on the whole I conclude that it was objectively reasonable for police to conclude that “defendant’s knowledge that his phone contained potential criminal evidence, and that police were actively investigating the circumstances of the crime, coupled with the ease of deleting evidence from cell phones” created an imminent risk of destruction of evidence from defendant’s phone. Id. at __; slip op at 7-8.

1 The majority finds it notable that defendant did not testify to possessing the same physical phone since 1990, but this does not undermine the basis for seizing defendant’s phone.

-2- Accordingly, regardless of whether defendant consented to the initial seizure of his phone, that seizure was valid. Woodard, 321 Mich App at 382-383.

A difference between this case and Evans is that the police in Evans obtained a warrant for the subsequent search of the defendant’s phone. See id. at ___; slip op at 3. In this case, the police did not do so, but that is simply because defendant opted to sign a form clearly indicating his consent to the search. The majority holds that this consent was coerced, based on the earlier conversation between defendant and the prosecutor in which the prosecutor informed defendant that his phone was going to be seized regardless of his consent, and that defendant would get his phone back faster if he consented to a search rather than requiring the prosecutor to obtain a search warrant. I disagree that defendant’s consent was coerced.

The record shows that the prosecutor gave defendant truthful information about what was happening with his cell phone and how his choices would impact the length of time until it would be returned to him. As stated, police and the prosecutor had probable cause to believe that evidence existed on defendant’s cell phone and held a legitimate concern that the information could be deleted from that cell phone. See Evans, ___ Mich App at ___; slip op at 5-6. Therefore, the prosecutor’s statements indicating that defendant had no choice about whether police seized his phone were factually and legally correct. Further, the prosecutor accurately informed defendant that the police could retain his phone for a reasonable time while pursuing a search warrant, and that he would then be separated from his phone for a longer period of time than if he consented to the search.

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People v. King
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People v. Goecke
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Bluebook (online)
People of Michigan v. James Douglas Frisbie, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-james-douglas-frisbie-michctapp-2025.