People v. Hayden

337 N.W.2d 258, 125 Mich. App. 650
CourtMichigan Court of Appeals
DecidedMay 17, 1983
DocketDocket 50046, 50142
StatusPublished
Cited by16 cases

This text of 337 N.W.2d 258 (People v. Hayden) 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 v. Hayden, 337 N.W.2d 258, 125 Mich. App. 650 (Mich. Ct. App. 1983).

Opinions

D. E. Holbrook, Jr., J.

Defendants were convicted by a jury on November 15, 1979, of attempted murder, MCL 750.91; MSA 28.286, rape, MCL 750.520; MSA 28.788 (repealed by 1974 PA 266), and larceny from a person, MCL 750.357; MSA 28.589. Each defendant was sentenced on December 13, 1979, to prison terms of from 30 to 50 years for rape, life for attempted murder, and from 6 to 10 years for larceny from a person. The sentences were to run consecutively with 22- to 40-year sentences imposed following defendants’ convictions at an earlier trial on another rape charge.

Defendants were originally tried by a jury in 1974 and found guilty on all three counts. Following their appeal this Court reversed the rape convictions and remanded for a new trial due to the trial court’s failure to specifically instruct that rape required sexual penetration; the convictions on the other two counts were affirmed. People v Wright, 71 Mich App 40; 246 NW2d 422 (1976).

Prior to retrial on the rape charge, defendants sought dismissal of the charge, alleging that the 180-day rule, MCL 780.131; MSA 28.969(1), had been violated. The circuit court denied the request, and defendants sought leave to appeal to this Court and to the Supreme Court; however, both requests were denied. See People v Wright (Docket No. 77-4364, order of February 27, 1978, lv den 402 Mich 950m (1978).

Defendants also sought leave in the Supreme Court for review of the Court of Appeals affirmance of the attempted murder and larceny convictions. In lieu of granting leave, the Court reversed the attempted murder and larceny from a person convictions and remanded for a new trial [655]*655"because the pretrial identification procedures were unnecessarily suggestive and because the trial judge erred when he determined that the questions raised by the pretrial identification procedures were for the jury, rather than him, to decide”. People v Hayden, 404 Mich 807; 280 NW2d 791 (1978).

Following defendants’ second jury trial on all three charges, they were found guilty. Defendants appeal to this Court, raising five common issues:

First, that the trial court erred in refusing to dismiss the rape charge where more than 180 days had elapsed between the date of reversal of defendants’ rape convictions by the Court of Appeals and the date of defendants’ new trial.

Second, that the circuit judge abused his discretion by examining a witness at the Wade1 hearing.

Third, that the circuit court erred in determining that there was an independent basis for the victim’s in-court identification of the defendant.

Fourth, that the trial court’s instructions to the jury were in error.

And, fifth, that the trial court committed reversible error by admitting, over objection, expert testimony regarding comparison of hair samples found in the back seat of defendant Wright’s vehicle and hair samples of the victim.

Defendants argue that the 180-day period should have begun to run on the date the prior opinion of the Court of Appeals was released, September 7, 1976. Defendants’ applications for leave to the Supreme Court were pending until December 29, 1978, when that Court reversed defendants’ attempted murder and larceny convictions, due to pretrial identification procedures, and remanded to [656]*656the circuit court for a new trial. See People v Hayden, 404 Mich 807 (1978). On February 20, 1979, the circuit court scheduled a new Wade hearing for the defendants.

In People v George, 399 Mich 638; 250 NW2d 491 (1977), the Court explained that, where leave to appeal is applied for in the Supreme Court from a decision of the Court of Appeals, the circuit court does not have jurisdiction to re-try the case until the application for leave to appeal is resolved. Since leave to appeal from the decision of the Court of Appeals had been applied for, the circuit court did not have jurisdiction to re-try defendants’ case. Shortly after the Supreme Court’s decision in the case, the circuit court began proceedings against defendants by scheduling a new Wade evidentiary hearing. This was within 180 days. Therefore, no violation of the 180-day rule occurred and the rape charges against the defendants should not have been dismissed.

During the Wade hearing, the judge questioned the victim. Defense counsel objected to the questioning. A judge has wide discretion and may properly participate in the questioning of a witness. People v Hanna, 85 Mich App 516, 520; 271 NW2d 299 (1978), lv den 406 Mich 893 (1979). One proper role of questioning by a judge is to clarify points and to elicit additional relevant information. People v Smith, 64 Mich App 263, 267; 235 NW2d 754 (1975). The major concern over judicial examination is that the judge’s questions might indicate some partiality to the jury and influence its verdict. See Hanna, supra, p 520; Smith, supra, p 267. It is when a case is being tried before a jury that a judge should. avoid any invasion of the prosecutor’s role. See People v Cole, 349 Mich 175, 196; 84 NW2d 711 (1957).

[657]*657The instant hearing was not held before a jury. The judge questioning the victim was also the finder of fact. A review of the judge’s questions reveals that the judge was clarifying points in eliciting additional relevant information. The judge did not, therefore, abuse his discretion in questioning at the Wade hearing. A new trial should not be granted on this issue.

With respect to defendants’ third issue, the Supreme Court held that the pretrial identification procedures used in this case were unnecessarily suggestive and that the trial court had erred in determining that the questions raised by the procedures were for the jury rather than the judge to decide. People v Hayden, 404 Mich 807 (1978).

Pursuant to the decision of the Supreme Court, a new Wade hearing was held to determine whether the victim could make an in-court identification of the defendants that was independent of any taint from the pretrial identification.

In People v Kachar, 400 Mich 78; 252 NW2d 807 (1977), the Supreme Court developed seven factors which a court should use in determining whether an independent basis for an in-court identification exists. After the Wade hearing, the circuit court considered these factors and enunciated its findings on the record. The trial court’s findings may not be set aside unless clearly erroneous. GCR 1963, 517.1. After our review of the court’s consideration of the factors in Hachar, we do not find them to be clearly erroneous. Hence, we will not reverse on this issue.

As to defendants’ claim that the trial court’s instructions to the jury were erroneous, we note that during the charge to the jury the judge commented on the fact that an expert witness had testified at trial. The judge informed the jurors [658]*658that they were not bound to follow the expert’s opinion, they should scrutinize the opinion, and they were to judge the expert in the same way they judge every other witness. It does not appear that the judge implied to the jury that more weight should be given the opinion of the expert than the other witnesses.

Although use of the Michigan Criminal Jury Instructions is encouraged, they are not mandatory. People v Turner,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

20250219_C365090_70_365090.Opn.Pdf
Michigan Court of Appeals, 2025
People of Michigan v. Brian Dewayne McElroy
Michigan Court of Appeals, 2024
People of Michigan v. Joel Edward Layman
Michigan Court of Appeals, 2024
People of Michigan v. Anthony Fareed
Michigan Court of Appeals, 2024
People of Michigan v. Frank James Horton
Michigan Court of Appeals, 2017
People v. Vettese
489 N.W.2d 514 (Michigan Court of Appeals, 1992)
People v. Kosters
438 N.W.2d 651 (Michigan Court of Appeals, 1989)
People v. Laidlaw
425 N.W.2d 738 (Michigan Court of Appeals, 1988)
West Michigan Park Ass'n v. Fogg
404 N.W.2d 644 (Michigan Court of Appeals, 1987)
State v. Harrison
357 N.W.2d 201 (Nebraska Supreme Court, 1984)
People v. Goree
349 N.W.2d 220 (Michigan Court of Appeals, 1984)
People v. Hayden
337 N.W.2d 258 (Michigan Court of Appeals, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
337 N.W.2d 258, 125 Mich. App. 650, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hayden-michctapp-1983.