People of Michigan v. Tyler Benjamin Sexton

CourtMichigan Court of Appeals
DecidedJune 5, 2026
Docket373611
StatusUnpublished

This text of People of Michigan v. Tyler Benjamin Sexton (People of Michigan v. Tyler Benjamin Sexton) 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. Tyler Benjamin Sexton, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 05, 2026 Plaintiff-Appellee, 11:44 AM

V No. 373611 Shiawassee Circuit Court TYLER BENJAMIN SEXTON, LC No. 2023-008201-FC

Defendant-Appellant.

Before: TREBILCOCK, P.J., and CAMERON and LIEVENSE, JJ.

PER CURIAM.

Defendant appeals as of right his jury trial convictions and sentences arising from a fatal car accident. He was convicted of involuntary manslaughter, MCL 750.321, operating while intoxicated causing death, MCL 257.625(4)(a), operating while intoxicated causing serious injury, MCL 257.625(5), operating while license suspended or revoked causing death, MCL 257.904(4), and operating while license suspended or revoked causing serious injury, MCL 257.904(5). The trial court sentenced defendant 10 to 15 years’ imprisonment each for the manslaughter, operating while intoxicated causing death, and operating without a license causing death convictions, and 38 to 60 months’ imprisonment each for the other convictions.

On appeal, defendant argues the trial court erred by denying his request for specific performance of a plea agreement, that prosecutorial misconduct occurred, and that the trial court failed to justify defendant’s upward departure sentences. For the reasons set forth in this opinion, we affirm defendant’s convictions and sentences.

I. FACTS

A. THE CAR CRASH, INJURIES, AND DEATH

On January 29, 2022, while his license was suspended, defendant was drinking, became intoxicated, got behind the wheel of a vehicle, and drove it through an intersection marked by a stop sign while traveling about 80 miles per hour. His vehicle collided with another vehicle at the

-1- intersection, causing a rollover accident that seriously injured the other driver and killed one of the two passengers in the vehicle that he struck. The other passenger, an infant, was unharmed. A subsequent blood test showed that defendant’s blood alcohol content was 0.159.

Defendant was charged in 2023 with second-degree murder, MCL 750.317, operating while intoxicated causing death, operating while intoxicated causing serious injury, operating while license suspended or revoked causing death, and operating while license suspended or revoked causing serious injury. B. PLEA NEGOTIATIONS AND PROCEDURAL BACKGROUND

After defendant’s arraignment and a probable cause conference, the parties began discussing a potential resolution of the case by plea. On September 11, 2023, the prosecuting attorney e-mailed defense counsel the following:

As promised here is the written plea offer with a waiver of his prelim.

Dismiss count 1. Plea to remaining counts. With the offer, my estimated guidelines are 50-100 [months].

As charged my estimated guidelines are 225-375/Life.

Please let me know if I don’t need to call witnesses for tomorrow.

Defense counsel responded that defendant “will be doing a voluntary bind-over to circuit court, at a minimum to keep the written plea offer in tact [sic].”

Defendant waived his preliminary examination. Next, defendant requested a Cobbs1 conference, which was held on October 19, 2023, for the parties and trial court to discuss the potential length of sentence that, on the basis of the information then available to the judge, appeared to be appropriate. The court declined to state a likely sentence. Thereafter, defense counsel called the prosecutor to request a Killebrew2 agreement for a sentence within the 50 to 100 month guidelines range. The prosecutor denied this request and no further discussion occurred.

Thus, in January 2024, defendant moved for specific performance of the plea offer outlined in the prosecutor’s September 2023 e-mail. At the hearing on the motion, defense counsel informed the court that the prosecution had made a new plea offer for second-degree murder if the defense withdrew the motion, then asked to withdraw the motion so that the parties could negotiate. The trial court granted defendant’s request. Those negotiations continued but apparently failed. Defendant then refiled the motion for specific performance of the original plea.

At the hearing on the renewed motion, defense counsel argued that specific performance was required because a condition of the plea deal was waiver of the preliminary examination,

1 People v Cobbs, 443 Mich 276, 283; 505 NW2d 208 (1993). 2 People v Killebrew, 416 Mich 189, 206-208; 330 NW2d 834 (1982).

-2- which defendant did, that defendant relied on the plea offer to his detriment by waiving his preliminary examination, and that the requests for a Killebrew agreement or a Cobbs hearing were not counteroffers and therefore did not signal rejection of the offer.

The court disagreed, finding that there was no evidence that defendant accepted any plea offer. It explained that defense counsel’s e-mail to the prosecuting attorney could not “reasonably be read as an acceptance of the plea agreement.” The court determined that defense counsel’s request for a Killebrew agreement amounted to a counteroffer rejecting the original offer, or, alternatively, if not a counteroffer, the Cobbs and Killebrew requests strongly indicated that the parties never reached a meeting of the minds concerning the original offer. It continued that if defendant thought he had accepted a plea early on, the defense would have requested a plea hearing, but he did not. The court also found that defendant did not detrimentally rely on the waiver of the preliminary examination. C. PRETRIAL AND TRIAL PROCEEDINGS

The prosecution filed a motion in limine to preclude evidence about seat belt use and defendant filed a motion in limine to preclude evidence of his prior criminal convictions and driving record. At a pretrial hearing on April 8, 2024, the day before trial, the court heard argument on the pretrial motions, and the prosecutor discussed defendant’s possible testimony at trial. The prosecutor stated that if defendant testified, “we may introduce evidence regarding his involvement with a[n] OWI [Operating While Intoxicated] charge and plea to impaired.” In response to a question about possible relevance, the prosecutor explained that the evidence “would indicate knowledge, on the part of the defendant, of the dangers of drunk driving.” The court suggested this might be impermissible propensity evidence, and the prosecutor conceded that the deadline for giving notice of the intent to introduce such evidence had passed. 3 On this issue, the court noted that “unless I see some law, that just seems like propensity . . . forbidden propensity. And . . . I don’t see how that would come in. Maybe there’s something out there . . . that would get it in. I’m just not seeing it.”

Trial commenced the next day. After the prosecution presented its case, defendant testified about the events of the day that led up to the crash, which included him going to a bar and drinking and eventually driving. On cross-examination, the prosecutor asked defendant a series of questions relevant to this appeal. The prosecutor asked without objection whether, before the date of the crash, defendant had driven without his license, and defendant admitted he had. The prosecutor and defendant next had the following exchange:

Q. Is that the first time you ever got behind the wheel after drinking?
A. No, sir.
Q. How many times do you estimate you did that?

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People of Michigan v. Tyler Benjamin Sexton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-tyler-benjamin-sexton-michctapp-2026.