People of Michigan v. Michael Joseph Kvasnicka

CourtMichigan Court of Appeals
DecidedJuly 21, 2025
Docket371542
StatusUnpublished

This text of People of Michigan v. Michael Joseph Kvasnicka (People of Michigan v. Michael Joseph Kvasnicka) 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. Michael Joseph Kvasnicka, (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, FOR PUBLICATION July 21, 2025 Plaintiff-Appellee, 9:27 AM

v No. 371542 Wayne Circuit Court MICHAEL JOSEPH KVASNICKA, LC No. 24-001354-01-FH

Defendant-Appellant.

ON REMAND

Before: BOONSTRA, P.J., and M. J. KELLY and MALDONADO, JJ.

M. J. KELLY, J.

This case involving the constitutionality of MCL 750.543m, a statute that criminalizes making a terrorist threat or making a false report of terrorism, returns to us on remand from our Supreme Court. People v Kvasnicka, ___ Mich ___; 18 NW3d 308 (2025) (Kvasnicka II). In our prior opinion, we concluded that MCL 750.543m was facially unconstitutional because, contrary to the United States Supreme Court’s decision in Counterman v Colorado, 600 US 66; 143 S Ct 2106; 216 L Ed 2d 775 (2023), the statute’s plain language does not require the prosecution to prove that the defendant acted recklessly, i.e., that he or she “consciously disregarded a substantial risk that his [or her] communications would be viewed as threatening violence.” People v Kvasnicka, ___ Mich App ___, ___; ___ NW3d ___ (2025) (Docket No. 371542); slip op at 5, vacated and remanded 18 NW3d 308 (2025) (Kvasnika I). In its order vacating Kvasnicka I, our Supreme Court did not express an opinion on the constitutionality of MCL 750.543m. Kvasnicka II, 18 NW3d at 308. Rather, the Court directed us to

address the proper interpretation of MCL 750.543m in light of: (1) MCL 750.543z, which provides that “a prosecuting agency shall not prosecute any person or seize any property for conduct presumptively protected by the first amendment to the constitution of the United States in a manner that violates any constitutional provision”; and (2) the constitutional-doubt canon, see Sole v Mich Econ Dev Corp, 509 Mich 406, 419-420; 983 NW2d 733 (2022). The Court of Appeals shall also address: (3) whether it is appropriate to adopt a limiting construction of MCL

-1- 750.543m to remedy any remaining constitutional deficiency, see People v Burkman, 513 Mich 300, 340; 15 NW3d 216 (2024); see also Osborne v Ohio, 495 US 103, 115; 110 S Ct 1691; 109 L Ed 2d 98 (1990); (4) if so, what that limiting construction should be; and (5) whether the Wayne Circuit Court abused its discretion by dismissing the case without prejudice on February 24, 2025, where doing so necessarily implicated “aspects of the case involved in the interlocutory appeal” while an application for leave to appeal remained pending with [the Michigan Supreme Court].” People v Scott, 513 Mich 180, 200; 15 NW3d 159 (2024); see MCR 7.215(F)(1)(a); MCR 7.305(C)(6)(a). [Id.]

Having considered these directives, we now conclude that MCL 750.543m(1)(a) is not facially unconstitutional. Accordingly, we affirm the trial court’s order denying defendant’s motion to dismiss the charges against him and remand for further proceedings consistent with this opinion.

I. DISMISSAL BY THE TRIAL COURT

We first address whether the trial court abused its discretion by dismissing this case without prejudice while an application for leave was pending in our Supreme Court. We conclude that it did. MCR 7.215(F)(1)(a) provides that, unless otherwise ordered by this Court or our Supreme Court, “the Court of Appeals judgment is effective after the expiration of the time for filing an application for leave to appeal in the Supreme Court, or, if such an application is filed, after the disposition of the case by the Supreme Court[.]” Additionally, MCR 7.305(C), provides in relevant part:

(6) If a party appeals a decision that remands for further proceedings as provided in subrule (C)(5)(a), the following provisions apply:

(a) If the Court of Appeals decision is a judgment under MCR 7.215(E)(1), an application for leave to appeal stays proceedings on remand unless the Court of Appeals or the Supreme Court orders otherwise.

In our prior opinion, issued on February 13, 2025, we reversed the trial court’s order denying Kvasnicka’s motion to dismiss and ordered the court to enter an order dismissing the charges. Kvasnicka I, ___ Mich App at ___; slip op at 5. The prosecution had 56 days to file an application for leave to appeal in the Supreme Court under MCR 7.305(C)(2), and it filed its application on February 20, 2025. At that point, the trial court remained divested of subject-matter jurisdiction. See People v Winburn, ___ Mich App ___, ___; ___ NW3d ___ (2025) (Docket No. 369323); slip op at 2-3 (holding that a trial court is divested of subject-matter jurisdiction upon the filing of a claim of appeal and, upon the filing of an application for leave to appeal to our Supreme Court, “jurisdiction remains with the appellate courts (and correspondingly, the circuit court remains divested of jurisdiction) until the Supreme Court’s ‘disposition of defendant’s application for leave to appeal the Court of Appeals’ judgment.’ ” (quoting People v Washington, 508 Mich 107, 127; 972 NW2d 767 (2021)). Contrary to the court rules, and in the absence of subject-matter jurisdiction, the trial court dismissed the case without prejudice on February 28, 2025, which was 15 days after this Court issued the opinion, and 8 days after the prosecution filed its application for leave to appeal. In doing so, the court abused its discretion.

-2- II. CONSTITUTIONALITY OF MCL 750.543m

A. STANDARD OF REVIEW

In its remand order, our Supreme Court has directed us to consider the proper interpretation of MCL 750.543m in light of MCL 750.543z and the constitutional-doubt canon of statutory interpretation. We review de novo questions related to the constitutionality of a statute. People v McKinley, 496 Mich 410, 415; 852 NW2d 770 (2014). We also review de novo the proper application and interpretation of a statute. Id. at 414-415.

B. ANALYSIS
1. CONSTITUTIONAL PRINCIPLES

We first consider the underlying constitutional principles applicable in this case. Although the states and the federal government are prohibited from making laws that abridge the freedom of speech, US Const Am I and Const 1963, art 1, § 5, it is well-established that “[t]rue threats of violence are outside the bounds of First Amendment protection and [are] punishable as crimes.” Counterman, 600 US at 69. “ ‘True threats’ encompass those statements where the speaker means to communicate a serious expression of intent to commit an act of unlawful violence to a particular individual or group of individuals.” Virginia v Black, 538 US 343, 359; 123 S Ct 1536; 155 L Ed 2d 535 (2003). “The speaker need not actually intend to carry out the threat. Rather, a prohibition on true threats protects individuals from the fear of violence and from the disruption that fear engenders, in addition to protecting people from the possibility that the threatened violence will occur.” Id. at 359-360 (quotation marks, alterations, and citation omitted). “The ‘true’ in that term distinguishes what is at issue from jests, ‘hyperbole,’ or other statements that when taken in context do not convey a real possibility that violence will follow (say, ‘I am going to kill you for showing up late’).” Counterman, 600 US at 74, citing Watts v United States, 394 US 705, 708; 89 S Ct 1399; 22 L Ed 2d 664 (1969). “Whether the speaker is aware of, and intends to convey, the threatening aspect of the message is not part of what makes a statement a threat[.]” Counterman, 600 US at 74, citing Elonis v United States, 575 US 723, 733; 135 S Ct 2001; 192 L Ed 2d 1 (2015).

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People of Michigan v. Michael Joseph Kvasnicka, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-michael-joseph-kvasnicka-michctapp-2025.