People v. Knight

Michigan Court of Appeals

People v. Knight

333 N.W.2d 94, 122 Mich. App. 584

CourtMichigan Court of Appeals

DecidedJanuary 20, 1983

DocketDocket 54393

StatusPublished

Cited by5 cases

This text of 333 N.W.2d 94 (People v. Knight) 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. Knight, 333 N.W.2d 94, 122 Mich. App. 584 (Mich. Ct. App. 1983).

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Opinions

Per Curiam.

We agree with Chief Judge Danhof’s analysis of all issues in this case except one. We do not believe that the trial court erred when admitting evidence of the defendant’s prior convictions. The "crimes of violence” standard used by the trial court is wrong. It appears nowhere in case law or the Rules of Evidence. But the judge did not base his decision solely on this standard. The record shows that the judge recognized his discretion and recognized both the prejudicial and probative elements in admitting evidence of similar crimes. People v Crawford, 83 Mich App 35, 39; 268 NW2d 275 (1978). By announcing that these were crimes of violence, the trial judge announced one wrong reason for admitting evidence of the convictions but this does not detract from the fact that he properly applied the Crawford factors in reaching his decision. Thus, the decision was not erroneous, despite the surplusage.

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Per Curiam.

We agree with Chief Judge Danhof’s analysis of all issues in this case except one. We do not believe that the trial court erred when admitting evidence of the defendant’s prior convictions. The "crimes of violence” standard used by the trial court is wrong. It appears nowhere in case law or the Rules of Evidence. But the judge did not base his decision solely on this standard. The record shows that the judge recognized his discretion and recognized both the prejudicial and probative elements in admitting evidence of similar crimes. People v Crawford, 83 Mich App 35, 39; 268 NW2d 275 (1978). By announcing that these were crimes of violence, the trial judge announced one wrong reason for admitting evidence of the convictions but this does not detract from the fact that he properly applied the Crawford factors in reaching his decision. Thus, the decision was not erroneous, despite the surplusage.

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Bluebook (online)

333 N.W.2d 94, 122 Mich. App. 584, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-knight-michctapp-1983.

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