People v. Cain

869 N.W.2d 829, 498 Mich. 108, 2015 Mich. LEXIS 1636
CourtMichigan Supreme Court
DecidedJuly 23, 2015
DocketDocket 149259
StatusPublished
Cited by147 cases

This text of 869 N.W.2d 829 (People v. Cain) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Cain, 869 N.W.2d 829, 498 Mich. 108, 2015 Mich. LEXIS 1636 (Mich. 2015).

Opinions

[112]*112[[Image here]]

This case presents a fundamental question that appellate courts often confront: whether to afford relief on the basis of a claim of error not raised in the trial court. As a general rule, appellate courts will not grant relief on belated claims of error unless the proponent establishes, among other things, that the unpreserved error seriously affected the fairness, integrity, or public reputation of the judicial proceedings. Defendant here, who raised for the first time on appeal a claim that the trial court gave the wrong juror’s oath, has failed to meet this burden. Our review of the record reveals that the jurors were conscious of the gravity of the task before them and the manner in which that task was to be carried out, the two primary purposes served by the juror’s oath. Thus, we cannot say that the error here of failing to properly swear the jury seriously affected the fairness, integrity, or public reputation of the judicial proceedings. We therefore vacate the Court of Appeals’ order holding to the contrary and reinstate defendant’s convictions and sentences.

I. FACTS AND HISTORY

On February 28,2012, Ashley Conaway and Abreeya Brown were abducted, tortured, and murdered. A month later, their bodies were found buried in a shallow grave, and defendant Brandon Cain and four others were charged in connection with the victims’ deaths.1 All five men were tried at a single trial with two separate juries, one for Cain and a codefendant [113]*113and another for the remaining codefendants. After three days of jury voir dire, defendant’s jury was selected. At the start of trial, the court instructed the jury, “I will now ask you to stand and swear to perform your duty to try the case justly and to reach a true verdict.” The clerk proceeded to swear in the jury, but mistakenly read the oath given to prospective jurors before voir dire:

The Clerk: You do solemnly swear or affirm that you will true answers make to such questions as may be put to you touching upon your qualifications to serve as jurors in the cause now pending before the Court [sic]?t21
[Jurors]: (Collectively) I do.

There was no objection to the failure to administer the proper oath, although no one disputes that the oath given was incorrect.3

A lengthy trial followed, at the end of which the jury convicted defendant as charged. He was sentenced to mandatory terms of life in prison without parole for the murder convictions and various lesser term-of-years sentences for the remaining convictions. On appeal, defendant raised for the first time a challenge to the trial court’s failure to properly swear the jury. Defendant’s appellate counsel filed a motion for peremptory reversal of his convictions, which the Court of Appeals granted in an order, stating, “The failure to properly swear the jury is a structural error requiring a new trial. People v Allan, 299 Mich App 205; 829 NW2d 319 (2013).” People v Cain, unpublished order of the Court of Appeals, entered May 2, 2014 (Docket No. 314342). The Court remanded “for a new trial with a properly sworn jury.” Id.

[114]*114The prosecutor then sought an appeal in this Court, and we granted leave to appeal on the following question:

[WJhether the Court of Appeals erred in determining that the failure to properly swear the jury, even in the absence of a timely objection, is a structural error requiring a new trial. [People v Cain, 497 Mich 861 (2014).]

II. STANDARD OF REVIEW

Whether the failure to properly swear the jury, even in the absence of a timely objection, requires that the defendant be afforded a new trial is a question of law, and such questions are reviewed de novo. People v Chenault, 495 Mich 142, 159; 845 NW2d 731 (2014).

III. ANALYSIS

A. UNPRESERVED ERRORS

Defendant did not object to the trial court’s failure to properly swear the jury. His claim on appeal and the Court of Appeals’ decision to afford relief therefore implicate the general and longstanding rule in Michigan that “issues that are not properly raised before a trial court cannot be raised on appeal absent compelling or extraordinary circumstances.” People v Grant, 445 Mich 535, 546; 520 NW2d 123 (1994). The essential justification for this rule is fairness, both to litigants, who are best equipped to respond to alleged errors at the time they occur, and to the public, which must bear the cost of new trials that could have been avoided with a timely objection. See People v Carines, 460 Mich 750, 764-765; 597 NW2d 130 (1999) (“[A] contemporaneous objection provides the trial court ‘an opportunity to correct the error, which could thereby obviate the necessity of further legal proceedings and [115]*115would be by far the best time to address a defendant’s constitutional and nonconstitutional rights.’ ”), quoting Grant, 445 Mich at 551. As this Court recently explained in People v Vaughn, 491 Mich 642, 653-654; 821 NW2d 288 (2012): “This Court ‘has long recognized the importance of preserving issues for appellate review.’As a result, ‘[t]his Court disfavors consideration of unpreserved claims of error,’ even unpreserved claims of constitutional error.” (Citations omitted; alteration in original.)

The United States Supreme Court has also long recognized the importance of preserving issues for appellate review. As it has explained:

If an error is not properly preserved, appellate-court authority to remedy the error (by reversing the judgment, for example, or ordering a new trial) is strictly circumscribed. There is good reason for this; “anyone familiar with the work of courts understands that errors are a constant in the trial process, that most do not much matter, and that a reflexive inclination by appellate courts to reverse because of unpreserved error would be fatal.”
This limitation on appellate-court authority serves to induce the timely raising of claims and objections, which gives the district court the opportunity to consider and resolve them. That court is ordinarily in the best position to determine the relevant facts and adjudicate the dispute. In the case of an actual or invited procedural error, the district court can often correct or avoid the mistake so that it cannot possibly affect the ultimate outcome. And of course the contemporaneous-objection rule prevents a litigant from “ ‘sandbagging ” the court—remaining silent about his objection and belatedly raising the error only if the case does not conclude in his favor. [Puckett v United States, 556 US 129, 134; 129 S Ct 1423; 173 L Ed 2d 266 (2009) (citations omitted).]

This is why the United States Supreme Court and this Court adopted the plain-error test in United States v [116]*116Olano, 507 US 725, 735-737; 113 S Ct 1770; 123 L Ed 2d 508 (1993), and Carines, 460 Mich at 763, respectively, and why Vaughn,

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Cite This Page — Counsel Stack

Bluebook (online)
869 N.W.2d 829, 498 Mich. 108, 2015 Mich. LEXIS 1636, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-cain-mich-2015.