People of Michigan v. Jason Lane Debandt

CourtMichigan Court of Appeals
DecidedMay 15, 2025
Docket366601
StatusUnpublished

This text of People of Michigan v. Jason Lane Debandt (People of Michigan v. Jason Lane Debandt) 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. Jason Lane Debandt, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED May 15, 2025 Plaintiff-Appellee, 11:48 AM

v No. 366601 Oakland Circuit Court JASON LANE DEBANDT, LC No. 2021-278536-FH

Defendant-Appellant.

Before: M. J. KELLY, P.J., and SWARTZLE and ACKERMAN, JJ.

PER CURIAM.

Defendant, Jason Debandt, appeals as of right his jury-trial convictions of two counts of third-degree criminal sexual conduct (CSC III), MCL 750.520d(1)(e)(i); one count of fourth- degree criminal sexual conduct (CSC IV), MCL 750.520e(1)(f)(i); and two counts of disseminating sexually explicit matter to a minor, MCL 722.675. Debandt was sentenced to 10 to 15 years’ imprisonment for each CSC III conviction; one to two years’ imprisonment for the CSC IV conviction; and one to two years’ imprisonment for each disseminating sexually explicit matter to a minor conviction. We affirm for the reasons stated in this opinion.

I. BASIC FACTS

Debandt’s convictions arise out of his inappropriate relationships with two high school students. During these relationships, Debandt was the choir and theater teacher at a high school. Debandt’s convictions comprise of three CSC counts, which were committed against KE at Debandt’s home; and the two counts of disseminating sexually explicit matter to a minor, which are related to Debandt’s sending explicit photographs and videos to VL when she was a minor. At trial, other-acts evidence was presented through the testimony of EF and MM, both of whom had sexual relationships with Debandt when they were high-school students.

-1- II. SUFFICIENCY OF THE EVIDENCE

A. STANDARD OF REVIEW

Debandt first argues that he was denied due process because the prosecution failed to present sufficient evidence to support his convictions. “We review de novo a challenge on appeal to the sufficiency of the evidence.” People v Henry, 315 Mich App 130, 135; 889 NW2d 1 (2016) (quotation marks and citation omitted).

B. ANALYSIS

“[D]ue process requires the prosecution to prove every element beyond a reasonable doubt.” People v Oros, 502 Mich 229, 240 n 3; 917 NW2d 559 (2018). There is sufficient evidence for a guilty verdict where “a rational trier of fact could find the defendant guilty beyond a reasonable doubt.” People v Tennyson, 487 Mich 730, 735; 790 NW2d 354 (2010) (quotation marks and citation omitted). “Circumstantial evidence and the reasonable inferences that arise from that evidence can constitute satisfactory proof of the elements of the crime.” People v Blevins, 314 Mich App 339, 357; 886 NW2d 456 (2016). Conflicts that arise in the evidence must be resolved “in favor of the prosecution.” People v Mikulen, 324 Mich App 14, 20; 919 NW2d 454 (2018). “It is the jury’s task to weigh the evidence and decide which testimony to believe.” People v Unger, 278 Mich App 210, 222; 749 NW2d 272 (2008) (quotation marks and citation omitted).

Debandt was convicted of two counts of CSC III under MCL 750.520d(1)(e)(i) for digital penetration of KE’s vagina and cunnilingus. The elements required the prosecution to prove that Debandt “engage[d] in sexual penetration with a public school student” when that student was “at least 16 years of age and less than 18 years of age.” People v Lewis, 302 Mich App 338, 344; 839 NW2d 37 (2013); MCL 750.520d(1)(e). Additionally, the prosecution had to establish that Debandt was a teacher when the sexual penetration occurred. MCL 750.520d(1)(e)(i). “ ‘Sexual penetration’ means . . . cunnilingus, . . . or any other intrusion, however slight, of any part of a person’s body or of any object into the genital or anal openings of another person’s body, but emission of semen is not required.” MCL 750.520a(r).

Additionally, Debandt was convicted of CSC IV under MCL 750.520e(1)(f)(i) for touching KE’s breasts. CSC IV requires the defendant to engage in sexual contact with another person. People v Green, 313 Mich App 526, 538; 884 NW2d 838 (2015). Additionally, because Debandt was charged under MCL 750.520e(1)(f)(i), the prosecution had to prove KE was “at least 16 years of age but less than 18 years of age and a student at a public school,” and Debandt was her “teacher. . . .” See MCL 750.520e(1)(f)(i). “[S]exual contact” includes the intentional touching of the victim’s or actor’s intimate parts or the intentional touching of the clothing covering the immediate area of the victim’s or actor’s intimate parts, if that intentional touching can reasonably be construed as being for the purpose of sexual arousal or gratification, done for a sexual purpose, or in a sexual manner[.]” MCL 750.520a(q). Breasts are an intimate part. MCL 750.520a(f). “[W]hen determining whether touching could be reasonably construed as being for a sexual purpose, the conduct should be viewed objectively under a reasonable person standard.” People v DeLeon, 317 Mich App 714, 719-720; 895 NW2d 577 (2016) (quotation marks and citation omitted).

-2- Here, KE testified that, when she was 16 years old, Debandt (1) digitally penetrated her vagina; (2) engaged in cunnilingus with her; and (3) touched her breasts. The sexual penetration and the sexual contact occurred within the same criminal transaction, while KE and Debandt were alone in his home. KE testified the assaults occurred when she was Debandt’s student. On appeal, Debandt argues that there was insufficient evidence to show that KE was a student under the age of 18 when the sexual penetration and sexual contact occurred. However, “[t]he victim’s testimony alone can provide sufficient evidence to support a conviction,” DeLeon, 317 Mich App at 719. He also maintains that her testimony lacked credibility and was financially motivated. But we defer to the jury’s credibility determinations when reviewing a claim of insufficient evidence. Unger, 278 Mich App at 222. Accordingly, viewing the evidence in a light most favorable to the prosecution, there was sufficient evidence to support Debandt’s convictions of CSC III and CSC IV.

Further, there was sufficient evidence to support Debandt’s convictions of disseminating sexually explicit matter to a minor. The elements are that the defendant knowingly disseminated to a minor sexually explicit visual or verbal material that is harmful to minors; (2) he was aware of the material’s sexually explicit character and content; and (3) he was either aware the person to whom the dissemination is made is under 18 years of age, or recklessly disregarded a substantial risk the person to whom the dissemination was made was under 18 years of age. MCL 722.675. Photographs and videos depicting “nudity, sexual excitement, [or] erotic fondling” are included within the definition of “sexually explicit visual material.” MCL 722.673(i); see also MCL 722.673(f) (defining “sexually explicit matter” to include “sexually explicit visual material.”). Dissemination includes giving, showing, or exhibiting such materials. MCL 722.671(b).

Here, VL estimated Debandt sent between 100 to 200 explicit photographs to her when she was between the ages of 16 and 17 years old. At least some of the photographs were of Debandt’s penis. Debandt also sent VL explicit videos, which included at least one video which depicted him ejaculating. VL saved some of the videos and photographs, and the materials were turned over to law enforcement. Some of the photographs and videos that Debandt sent to VL were admitted into evidence and published to the jury. See People v Brown, 326 Mich App 185, 192; 926 NW2d 879 (2018) (holding photographs may be used to corroborate the testimony of a witness).

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People of Michigan v. Jason Lane Debandt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-jason-lane-debandt-michctapp-2025.