People v. Duncan

610 N.W.2d 551, 462 Mich. 47
CourtMichigan Supreme Court
DecidedMay 23, 2000
DocketDocket 112997
StatusPublished
Cited by104 cases

This text of 610 N.W.2d 551 (People v. Duncan) 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. Duncan, 610 N.W.2d 551, 462 Mich. 47 (Mich. 2000).

Opinions

Per Curiam.

A jury convicted the defendant of two counts of first-degree murder and two counts of felony-firearm. The Court of Appeals affirmed. We reverse the felony-firearm convictions because the jury was not instructed on any of the elements of that offense.

We issue this opinion to iterate a bright line rule: It is structural error requiring automatic reversal to allow a jury to deliberate a criminal charge where there is a complete failure to instruct the jury regarding any of the elements necessary to determine if the prosecution has proven the charge beyond a reasonable doubt.

i

In late 1994, the defendant used a shotgun to kill two persons. They were his former spouse and a man to whom she had been married before she wed the defendant. The decedents had remained good friends, [49]*49and the defendant apparently would not accept his former spouse’s preference for the company of the other man.

The defendant was charged with two counts of first-degree (premeditated) murder1 and two counts of possessing a firearm during the commission of the murders.2

In introductory remarks to the prospective jurors, the circuit court read the felony-firearm charges in the information. The court thus told them that the prosecutor was alleging that the defendant

did carry or have in his possession a firearm—to-wit: a shotgun—at the time he committed or attempted to commit a felony—to-wit: premeditated murder.

The court added, “It’s known as felony firearm.”

After hearing prosecution and defense witnesses, as well as closing argument, the jurors were instructed by the court. In the course of these instructions, they learned the elements of first- and second-degree murder, and of voluntary manslaughter. However, the court entirely omitted any instruction regarding the elements of felony-firearm.3 Indeed, the only mention [50]*50of felony-firearm was in relation to the verdict form.4 Defense counsel did not object to the omission.

The jury found the defendant guilty of the murders and both counts of felony-firearm. The circuit court then imposed the mandatory sentences of life for first-degree murder and two-years for felony-firearm.5 Later, the court denied the defendant’s motion for new trial.

After the Court of Appeals affirmed,6 the defendant applied to this Court for leave to appeal. Initially, we held the case in abeyance7 pending the decision in People v Carines, 460 Mich 750; 597 NW2d 130 (1999). Now that Carines has been decided, the present case is again before us.

ii

The Court of Appeals found that it was error for the circuit court not to instruct the jury regarding the elements of the felony-firearm charges.8 It neverthe[51]*51less affirmed the felony-firearm convictions on the ground that the error was harmless beyond a reasonable doubt utilizing either Justice Brickley’s lead opinion in People v Vaughn, 447 Mich 217, 238, n 17; 524 NW2d 217 (1994), or the test stated in Justice Levin’s dissent in Vaughn. 447 Mich 272.

in

As explained in People v Grant, 445 Mich 535; 520 NW2d 123 (1994), constitutional error such as occurred here must be classified as either structural or nonstructural. If the error is structural, reversal is automatic. People v Anderson (After Remand), 446 Mich 392, 404-405; 521 NW2d 538 (1994). If the constitutional error is not structural, it is subject to the harmless beyond a reasonable doubt test. Id. The United States Supreme Court recently explained that most constitutional errors can be harmless, but that a limited class of constitutional errors are structural and subject to automatic reversal. Neder v United States, 527 US 1, 8; 119 S Ct 1827; 144 L Ed 2d 35 (1999).

Structural errors, as explained in Neder, are intrinsically harmful, without regard to their effect on the outcome, so as to require automatic reversal. Id. at 7. Such an error necessarily renders unfair or unreliable the determining of guilt or innocence. As the United States Supreme Court said in Rose v Clark, 478 US [52]*52570, 577-578; 106 S Ct 3101; 92 L Ed 2d 460 (1986), structural errors deprive defendants of basic protections without which a criminal trial cannot reliably serve its function as a vehicle for determination of guilt or innocence.9

The Court in Neder stated as follows citing several examples of structural error:

Indeed, we have found an error to be “structural,” and thus subject to automatic reversal, only in a “very limited class of cases.” Johnson v United States, 520 US 461, 468; 117 S Ct 1544; 137 L Ed 2d 718 (1997) (citing Gideon v Wainwright, 372 US 335; 83 S Ct 792; 9 L Ed 2d 799 (1963) (complete denial of counsel); Tumey v Ohio, 273 US 510; 47 S Ct 437; 71 L Ed 749 (1927) (biased trial judge); Vasquez v Hillery, 474 US 254; 106 S Ct 617; 88 L Ed 2d 598 (1986) (racial discrimination in selection of grand jury); McKaskle v Wiggins, 465 US 168; 104 S Ct 944; 79 L Ed 2d 122 (1984) (denial of self-representation at trial); Waller v Georgia, 467 US 39; 104 S Ct 2210; 81 L Ed 2d 31 (1984) (denial of public trial); Sullivan v Louisiana, 508 US 275; 113 S Ct 2078; 124 L Ed 2d 182 (1993) (defective reasonable-doubt instruction). [Id. at 8.]

In the situation in the case at bar, the defendant was deprived of a “basic protection.” The trial court’s failure to instruct regarding any of the elements of felony-firearm, while allowing the jury to render a verdict on felony-firearm, sent the jury to its deliberative duties deprived of its essential tool: the law that was to be applied to the facts.10 Such a defect improp[53]*53erly left the jury to speculate, i.e., the absence of any instructions regarding the elements of felony-firearm left the jury to guess what the prosecuting attorney might be required to prove. As we stated in People v Lambert, 395 Mich 296, 304; 235 NW2d 338 (1975), juries cannot be allowed to speculate. The court must inform the jury of the law by which its verdict must be controlled.11 Incontrovertibly, when a jury is allowed to speculate, the subsequent verdict is not a rehable indicator of the defendant’s guilt or lack thereof.

It is also possible that the failure to provide any of the elements of the charge may have suggested to the jury that the two charges were tie-barred, i.e., if the jury found defendant guilty of murder, they were then to find defendant guilty of felony-firearm. Such tie-barring would rim counter to our fundamental constitutional law as it directs the jury to return a verdict. Rose explained that a court may not direct a verdict of guilty against a defendant no matter how clear the defendant’s culpability. Rose, supra at 578.

[54]*54The reason for this is the Sixth Amendment’s clear command that the state must afford a trial with a jury at the defendant’s request in serious criminal cases. Duncan v Louisiana,

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Cite This Page — Counsel Stack

Bluebook (online)
610 N.W.2d 551, 462 Mich. 47, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-duncan-mich-2000.