Michigan Supreme Court Lansing, Michigan
Syllabus Chief Justice: Justices: Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas Noah P. Hood
This syllabus constitutes no part of the opinion of the Court but has been Reporter of Decisions: prepared by the Reporter of Decisions for the convenience of the reader. Kimberly K. Muschong
PEOPLE v ROBINSON
Docket No. 167595. Argued on application for leave to appeal October 9, 2025. Decided February 4, 2026.
In 2013, a jury convicted defendant, Todd D. Robinson, of first-degree premeditated murder, MCL 750.316(1)(a), and possession of a firearm during the commission of a felony (felony-firearm), MCL 750.227b, after a judge in the Jackson Circuit Court, acting as a one-person grand jury under MCL 767.3 and MCL 767.4, filed a two-count indictment against him. Before trial, defendant had unsuccessfully moved the trial court to either hold a preliminary examination or quash the information. Defendant’s direct appeal of his convictions failed, as did his first motion for relief from judgment. After the decision in People v Peeler, 509 Mich 381 (2022)—which held that a defendant charged under MCL 767.3 and MCL 767.4 is entitled to a preliminary examination and that these statutes do not authorize a judge serving as a one-person grand jury to issue a criminal indictment—defendant filed a second motion for relief from judgment in the Jackson Circuit Court, asserting that Peeler applied retroactively and that it entitled him to relief. Defendant also argued that because his indictment was invalid under Peeler, the circuit court never obtained subject-matter jurisdiction over his case and his convictions were therefore void. The trial court, Thomas D. Wilson, J., denied the motion, ruling that Peeler does not apply retroactively and that, even if it did, defendant could not establish prejudice as required by MCR 6.508(D)(3)(b) because the jury convicted him after a fair trial. The Court of Appeals, CAMERON, P.J., and N. P. HOOD and YOUNG, JJ., affirmed in a published opinion, holding that although defendant’s indictment violated the principles expressed in Peeler, that decision did not implicate subject- matter jurisdiction, announce a new rule of law, or apply retroactively on collateral review. ___ Mich App ___ (June 13, 2024) (Docket No. 365226). Defendant sought leave to appeal in the Supreme Court, which ordered oral argument on the application and directed the parties to address (1) whether the initiation of this case by an indictment filed by a judge acting as a one-person grand jury under MCL 767.3 and MCL 767.4 without conducting a preliminary examination, contrary to Peeler, deprived the Jackson Circuit Court of subject-matter jurisdiction and rendered the indictment void ab initio; (2) whether Peeler clearly established a new principle of law; (3) if Peeler clearly established a new principle of law, whether Peeler applies retroactively to cases pending on collateral review; and (4) whether defendant was entitled to relief from judgment under MCR 6.502(G) and MCR 6.508(D). ___ Mich ___; 14 NW3d 429 (2024). In a unanimous opinion by Justice WELCH, the Supreme Court, in lieu of granting leave to appeal, held:
Under Peeler, a judge sitting as a one-person grand jury pursuant to MCL 767.3 and MCL 767.4 may not issue a criminal indictment, and a defendant may not be charged under this statutory scheme without a preliminary examination. The Court of Appeals correctly concluded that Peeler does not apply retroactively on collateral review and that violations of Peeler’s holdings do not implicate a circuit court’s subject-matter jurisdiction, and it therefore did not err by affirming the trial court’s denial of defendant’s successive motion for relief from judgment. However, the panel erred by concluding that Peeler did not announce a new rule of law. Accordingly, this aspect of the panel’s decision was vacated, and the Court of Appeals judgment was affirmed on alternative grounds.
1. Under MCR 6.502(G)(2), subsequent motions for relief from judgment are generally prohibited unless an exception applies, such as a claim of new evidence or a retroactive change in law that occurred after the first motion for relief from judgment was filed, or the trial court lacked subject-matter jurisdiction over the trial.
2. MCL 767.3 and MCL 767.4 constitute a statutory scheme commonly known as the “one-man grand jury law,” which authorizes judges conducting criminal inquiries to subpoena witnesses and issue arrest warrants. Although the law does not state that a judge sitting as a one- person grand jury may issue an indictment, judges sometimes did so without providing defendants with a preliminary examination. Peeler ended that practice by holding that a defendant subjected to a one-person grand jury is entitled to a preliminary examination before proceeding to trial and that a judge may not issue a criminal indictment under the one-man grand jury law. Peeler did not address subject-matter jurisdiction or whether it would apply retroactively on collateral review.
3. Peeler did not implicate subject-matter jurisdiction. Subject-matter jurisdiction is the right of the court to exercise jurisdiction over a class of cases, and it is therefore not dependent on the particular facts of the case but rather on the character or class of the case pending. For that reason, although an improper charging document might implicate a circuit court’s in personam jurisdiction over a defendant, it does not implicate a circuit court’s subject-matter jurisdiction. It was undisputed that defendant’s case was a criminal matter, and it was similarly undisputed that circuit courts have subject-matter jurisdiction over that class of cases. Accordingly, the fact that the charging procedure was erroneous did not implicate the circuit court’s subject-matter jurisdiction over the case, nor, for similar reasons, did the lack of a preliminary examination strip the circuit court of its subject-matter jurisdiction.
4. The Court of Appeals correctly held that Peeler does not apply retroactively on collateral review under MCR 6.502(G)(2)(a), but it erred by concluding that Peeler did not announce a new rule of law. As a general matter, judicial decisions that express new rules are not applied retroactively to other cases that have become final. A rule of law is considered new either when an established precedent is overruled or when an issue of first impression is decided that was not adumbrated by an earlier appellate decision—in other words, when the result was not dictated by precedent existing when the defendant’s conviction became final. Peeler established a new rule of law because it ended the existing and judicially accepted practice of allowing one-person grand juries to issue indictments, because it decided this issue as a matter of first impression, and because no existing precedent dictated that the trial court in Peeler reject the legitimacy of the indictment. Accordingly, under the federal test, Peeler was presumed not to apply retroactively unless it constituted a new substantive rule of constitutional law, which it did not: Peeler’s rule was not substantive because it concerned the process of getting to trial and the manner of determining a defendant’s culpability rather than categorical constitutional guarantees that place certain criminal laws and punishment beyond the state’s power to impose, and it was not constitutional in nature but rather statutory. To determine whether a decision applies retroactively under the state test, a court considers the factors set forth in Linkletter v Walker, 381 US 618 (1965), and adopted in People v Hampton, 384 Mich 669 (1971): (1) the purpose of the new rule, (2) the general reliance on the old rule, and (3) the effect on the administration of justice. The Linkletter-Hampton factors weighed against Peeler’s retroactive application because (1) Peeler concerns the process of getting to trial, not the fairness of the trial itself; (2) it was undisputed that, before Peeler, prosecutors and judges relied on the assumption that the one-man grand jury law allowed judges to issue criminal indictments; and (3) the practice appeared to have been used with some regularity over many decades in some courts, and calling the resulting convictions into question when they resulted from fair trials that applied the most stringent beyond-a-reasonable-doubt standard would unnecessarily hinder the administration of justice in Michigan. Accordingly, the Linkletter-Hampton factors did not support applying Peeler retroactively on collateral review.
Court of Appeals judgment affirmed in part on alternative grounds and vacated in part.
Justice HOOD did not participate because he was on the Court of Appeals panel that issued the decision under review. Michigan Supreme Court Lansing, Michigan
OPINION Chief Justice: Justices: Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas Noah P. Hood
FILED February 4, 2026
STATE OF MICHIGAN
SUPREME COURT
PEOPLE OF THE STATE OF MICHIGAN,
Plaintiff-Appellee,
v No. 167595
TODD DOUGLAS ROBINSON,
Defendant-Appellant.
BEFORE THE ENTIRE BENCH (except HOOD, J.)
WELCH, J. The so-called “one-man grand jury law,” MCL 767.3 and MCL 767.4, authorizes
judges to investigate criminal offenses, subpoena witnesses, and issue arrest warrants. In
People v Peeler, 509 Mich 381, 394; 984 NW2d 80 (2022), we held that defendants charged
under the one-man grand jury law are entitled to a preliminary examination. We also held
that a judge serving as a one-person grand jury may not issue a criminal indictment. Id. at
395. The questions in this appeal are whether the errors we addressed in Peeler implicate a circuit court’s subject-matter jurisdiction and whether Peeler applies retroactively on
collateral review.
We agree with the Court of Appeals that the answer to both questions is no. We
disagree, however, with the panel’s conclusion that Peeler did not announce a new rule of
law. Accordingly, we affirm the Court of Appeals’ judgment on alternative grounds, and
we vacate the aspects of the panel’s analysis that are inconsistent with this opinion.
I. BACKGROUND
In 2012, a circuit judge acting as a one-person grand jury filed an indictment that
charged defendant Todd Douglas Robinson with open murder, MCL 750.318, and
possession of a firearm during the commission of a felony (felony-firearm), MCL
750.227b. Defendant moved the trial court to hold a preliminary examination or,
alternatively, to quash the information. The trial court denied that motion, and the jury
convicted defendant of first-degree premeditated murder, MCL 750.316(1)(a), and
felony-firearm. Defendant’s direct appeal failed, as did his first motion for relief from
judgment.
After we issued our opinion in Peeler, defendant filed the instant motion for relief
from judgment, which is his second. Through that motion, defendant asserted that Peeler
applied retroactively and that it entitled him to relief. Defendant also argued that because
his indictment was invalid under Peeler, the circuit court never obtained subject-matter
jurisdiction over his case. As a result, defendant argued, his convictions are null and void.
The trial court denied the motion and held that Peeler does not apply retroactively.
Even if it did, the trial court reasoned, defendant could not establish prejudice because the
2 jury convicted defendant after a fair trial. See MCR 6.508(D)(3)(b) (requiring a defendant
seeking relief from judgment to establish that the alleged irregularities resulted in
prejudice). The trial court did not address defendant’s arguments concerning subject-
matter jurisdiction.
The Court of Appeals affirmed in a published opinion. People v Robinson, ___
Mich App ___; ___ NW3d ___ (June 13, 2024) (Docket No. 365226). The panel held that
although defendant’s indictment violated the principles expressed in Peeler, (1) Peeler
does not implicate subject-matter jurisdiction, and (2) Peeler does not apply retroactively
on collateral review. In reaching the latter holding, the panel held that Peeler did not
announce a new rule of law. Defendant then applied to this Court for leave to appeal.
We ordered oral argument on the application. Our order directed the parties to
address:
(1) whether the initiation of this case by an indictment filed by a judge acting as a one-man grand jury under MCL 767.3 and MCL 767.4, and without a preliminary examination, contrary to People v Peeler, 509 Mich 381 (2022), deprived the Jackson Circuit Court of subject-matter jurisdiction and rendered the indictment void ab initio; (2) whether Peeler “ ‘clearly establishe[d] a new principle of law;’ ” League of Women Voters v Sec’y of State, 508 Mich 520, 565 (2022), quoting Pohutski v City of Allen Park, 465 Mich 675, 696 (2002); (3) if Peeler clearly established a new principle of law, whether Peeler applies retroactively to cases pending on collateral review; and (4) whether the defendant is entitled to relief from judgment under MCR 6.502(G) and MCR 6.508(D). [People v Robinson, ___ Mich ___, ___; 14 NW3d 429, 429 (2024).]
II. LEGAL BACKGROUND
A. STANDARD OF REVIEW
We review a trial court’s decision on a motion for relief from judgment for an abuse
of discretion. People v Christian, 510 Mich 52, 74; 987 NW2d 29 (2022). A trial court
3 abuses its discretion when it “makes a decision that falls outside the range of reasonable
and principled outcomes or makes an error of law.” Id. at 75 (quotation marks and citations
omitted). We review de novo whether a trial court lacked subject-matter jurisdiction over
a defendant’s trial. People v Washington, 508 Mich 107, 121; 972 NW2d 767 (2021).
Finally, whether a judicial opinion applies retroactively is a question of law that we review
de novo. People v Maxson, 482 Mich 385, 387; 759 NW2d 817 (2008).
B. PROCEDURAL BAR
Defendant appeals the trial court’s denial of his second motion for relief from
judgment. Our rules generally prohibit second or subsequent motions for relief from
judgment. See MCR 6.502(G)(2). There are, however, exceptions to that bar. A defendant
may file a second or subsequent motion for relief from judgment based upon:
(a) a retroactive change in law that occurred after the first motion for relief from judgment was filed,
(b) a claim of new evidence that was not discovered before the first such motion was filed, or
(c) a final court order vacating one or more of the defendant’s convictions either described in the judgment from which the defendant is seeking relief or upon which the judgment was based. [MCR 6.502(G)(2). 1]
A court may waive the provisions of MCR 6.502(G)(2), however, “if it concludes that there
is a significant possibility that the defendant is innocent of the crime.” Id. Finally, the bar
1 Although not relevant here, we note that the third exception was adopted shortly before the trial court entered the order at issue in this case and had not yet become effective. See Amendment of Rule 6.502, 510 Mich cxxxi, cxxxii (2022) (adopting MCR 6.502(G)(2)(c) effective January 1, 2023).
4 against successive motions for relief from judgment does not apply if a trial court lacked
subject-matter jurisdiction over the trial. Washington, 508 Mich at 131.
C. THE ONE-MAN GRAND JURY LAW
“Enacted in 1917, MCL 767.3 and MCL 767.4 are part of a statutory scheme that
quickly became known as the ‘one man grand jury’ law.” Peeler, 509 Mich at 389, citing
People v Doe, 226 Mich 5, 6; 196 NW 757 (1924). The law authorizes judges conducting
criminal inquiries to subpoena witnesses and issue arrest warrants. See MCL 767.3 and
MCL 767.4. Despite the law’s nickname, however, the governing statutes do not state that
a judge sitting as a one-person grand jury may issue an indictment. Peeler, 509 Mich at
396. Nevertheless, for many years, “the power of a judge conducting an inquiry to issue
an indictment was simply an unchallenged assumption . . . .” Id. at 399. Based upon that
assumption, Michigan judges acting under the one-man grand jury law sometimes issued
indictments without providing defendants with a preliminary examination. See id.
Peeler ended that practice. As explained earlier, Peeler held that (1) defendants
subjected to a one-person grand jury are entitled to a preliminary examination before
proceeding to trial and (2) a judge may not issue a criminal indictment under the one-man
grand jury law. Id. at 400. Relevant to this appeal, Peeler never mentions subject-matter
jurisdiction, nor does it address whether it would apply retroactively on collateral review.
III. DISCUSSION
Defendant argues that because his indictment was improper under Peeler, the trial
court lacked subject-matter jurisdiction over his trial. The parties also discuss whether
Peeler applies retroactively on collateral review. If either issue is resolved in defendant’s
5 favor, he would clear the procedural bar against successive motions for relief from
judgment. See MCR 6.502(G)(2)(a); Washington, 508 Mich at 131. We address both
issues in turn.
A. WHETHER PEELER IMPLICATES SUBJECT-MATTER JURISDICTION
“Subject-matter jurisdiction is a legal term of art that concerns a court’s authority to
hear and determine a case.” Washington, 508 Mich at 121, citing Bowie v Arder, 441 Mich
23, 36; 490 NW2d 568 (1992). If a circuit court lacked subject-matter jurisdiction over a
trial, any subsequent judgment is void ab initio. Washington, 508 Mich at 129-130. That
rule applies on a successive motion for relief from judgment. Id. at 131. A judgment is
not void, however, when there are jurisdictional or procedural issues that do not implicate
subject-matter jurisdiction. People v Scott, 513 Mich 180, 212; 15 NW3d 159 (2024). The
dispositive issue, therefore, is whether the trial court had subject-matter jurisdiction over
defendant’s trial. If it did not, then defendant’s conviction would be void ab initio.
Washington, 508 Mich at 129-130.
Michigan courts do not have inherent subject-matter jurisdiction. Id. at 121.
Instead, the courts derive subject-matter jurisdiction “from our constitutional and statutory
provisions.” Id. Our Constitution gives circuit courts “original jurisdiction in all matters
not prohibited by law[.]” Const 1963, art 6, § 13. In addition, MCL 600.601 provides:
(1) The circuit court has the power and jurisdiction that is any of the following:
(a) Possessed by courts of record at the common law, as altered by the state constitution of 1963, the laws of this state, and the rules of the supreme court.
6 (b) Possessed by courts and judges in chancery in England on March 1, 1847, as altered by the state constitution of 1963, the laws of this state, and the rules of the supreme court.
(c) Prescribed by the rules of the supreme court.
Based upon these constitutional and statutory provisions, “[s]ubject matter jurisdiction is
presumed unless expressly denied by constitution or statute.” People v Goecke, 457 Mich
442, 458; 579 NW2d 868 (1998), citing Bowie, 441 Mich at 38.
Of particular relevance to this case is the fact that subject-matter jurisdiction “is the
right of the court to exercise jurisdiction over a class of cases, such as criminal cases.”
Goecke, 457 Mich at 458 (emphasis added). Thus, subject-matter jurisdiction “is ‘not
dependent on the particular facts of the case’ but, instead, is dependent on the character or
class of the case pending.” Washington, 508 Mich at 121, quoting People v Lown, 488
Mich 242, 268; 794 NW2d 9 (2011) (emphasis added). For that reason, improper charging
documents do not implicate a circuit court’s subject-matter jurisdiction. Goecke, 457 Mich
at 458-459. See also In re Elliott, 315 Mich 662, 675; 24 NW2d 528 (1946). After all,
improper charging documents do not affect whether a circuit court has the right to exercise
jurisdiction over criminal cases generally. Instead, an improper charging document may
implicate a circuit court’s in personam jurisdiction over a defendant. 2 Goecke, 457 Mich
at 459.
2 As our cases have made clear, a circuit court’s jurisdiction remains “limited to [the offenses] specified in the return made by the examining magistrate.” People v Curtis, 389 Mich 698, 708; 209 NW2d 243 (1973), citing People v Evans, 72 Mich 367; 40 NW 473 (1888). See also People v Dochstader, 274 Mich 238, 244-245; 264 NW 356 (1936). Our holding today does nothing to disturb this settled precedent.
7 With those principles in mind, we hold that a Peeler violation does not implicate a
circuit court’s subject-matter jurisdiction. It is undisputed that defendant’s case was a
criminal matter, and it is similarly undisputed that circuit courts have subject-matter
jurisdiction over that “class of cases.” Goecke, 457 Mich at 458. The fact that the charging
procedure was erroneous thus did not implicate the circuit court’s subject-matter
jurisdiction over the case. Id. at 458-459. For similar reasons, the lack of a preliminary
examination did not strip the circuit court of its subject-matter jurisdiction. We therefore
affirm the judgment of the Court of Appeals on this issue.
B. WHETHER PEELER APPLIES RETROACTIVELY ON COLLATERAL REVIEW
Jurisdiction aside, the Court of Appeals also held that Peeler does not apply
retroactively on collateral review under MCR 6.502(G)(2)(a). We agree with this
conclusion, albeit on different grounds.
As a general matter, “judicial decisions which express new rules normally are not
applied retroactively to other cases that have become final.” People v Barnes, 502 Mich
265, 268; 917 NW2d 577 (2018). When determining whether an opinion applies
retroactively, therefore, the Court must first consider the “threshold question” of whether
that “decision amounts to a new rule of law.” League of Women Voters v Secretary of
State, 508 Mich 520, 566; 975 NW2d 840 (2022).
“ ‘A rule of law is new for purposes of resolving the question of its retroactive
application . . . either when an established precedent is overruled or when an issue of first
impression is decided which was not adumbrated by any earlier appellate decision.’ ” Id.,
quoting People v Phillips, 416 Mich 63, 68; 330 NW2d 366 (1982) (ellipsis in League of
8 Women Voters). Put another way, “ ‘a case announces a new rule if the result was not
dictated by precedent existing at the time the defendant’s conviction became final.’ ”
People v Walker, 328 Mich App 429, 438; 938 NW2d 31 (2019), quoting Chaidez v United
States, 568 US 342, 347; 133 S Ct 1103, 185 L Ed 2d 149 (2013).
The Court of Appeals held that Peeler did not announce a new rule of law. We
disagree. First, Peeler unquestionably ended the existing and judicially accepted practice
of allowing one-person grand juries to issue indictments. See Peeler, 509 Mich at 399 (“It
seems that the power of a judge conducting an inquiry to issue an indictment was simply
an unchallenged assumption, until now.”) (emphasis added). Second, Peeler decided “ ‘an
issue of first impression . . . which was not adumbrated by any earlier appellate decision.’ ”
League of Women Voters, 508 Mich at 566, quoting Phillips, 416 Mich at 68. Until Peeler,
no appellate court had ruled on whether the one-man grand jury law allowed judges to issue
indictments. Finally, no existing precedent dictated that the trial court in Peeler reject the
legitimacy of the indictment. See Walker, 328 Mich App at 438.
Because Peeler established a new rule of law, we presume that it does not apply
retroactively. See Barnes, 502 Mich at 268. But our inquiry does not end there. The
United States Supreme Court has explained that “courts must give retroactive effect to new
substantive rules of constitutional law.” Montgomery v Louisiana, 577 US 190, 198; 136
S Ct 718; 193 L Ed 2d 599 (2016). See also Barnes, 502 Mich at 271-272. We must
therefore determine whether Peeler announced a new substantive rule of constitutional
law. 3 “Substantive rules include ‘rules forbidding criminal punishment of certain primary
3 Until 2021, United States Supreme Court precedent provided two exceptions to the presumption against retroactivity: (1) opinions announcing a new substantive rule of
9 conduct,’ as well as ‘rules prohibiting a certain category of punishment for a class of
defendants because of their status or offense.’ ” Montgomery, 577 US at 198, quoting
Penry v Lynaugh, 492 US 302, 330; 109 S Ct 2934; 106 L Ed 2d 256 (1989).
Peeler did not announce a new substantive rule of constitutional law. First, Peeler
concerned the process of getting to trial. Peeler, 509 Mich at 400. It did not concern
“ ‘categorical constitutional guarantees that place certain criminal laws and punishment
altogether beyond the State’s power to impose.’ ” People v Poole, ___ Mich ___, ___; ___
NW3d ___ (January 22, 2025) (Docket No. 166813); slip op at 10, quoting Montgomery,
577 US at 201. Instead, Peeler regulated “ ‘the manner of determining [a] defendant’s
culpability.’ ” Id. at ___; slip op at 10, quoting Montgomery, 577 US at 201. Second, our
holding in Peeler was “statutory,” not constitutional. Peeler, 509 Mich at 400.
Consequently, the federal test does not demand retroactive application of Peeler.
Having determined that Peeler does not apply retroactively under the federal
retroactivity test for new rules, we “must also consider whether [the opinion] applies
retroactively on state-law grounds.” Barnes, 502 Mich at 273. To do so, we apply the
Linkletter-Hampton factors. See id. at 273 n 5; Poole, ___ Mich at ___; slip op at 6. See
also People v Hampton, 384 Mich 669; 187 NW2d 404 (1971); Linkletter v Walker, 381
US 618; 85 S Ct 1731; 14 L Ed 2d 601 (1965). Those factors are: “ ‘(1) the purpose of the
constitutional law, and (2) opinions announcing “a ‘watershed rule’ of criminal procedure.” Barnes, 502 Mich at 271, quoting Montgomery, 577 US at 198. In Edwards v Vannoy, 593 US 255, 272; 141 S Ct 1547; 209 L Ed 2d 651 (2021), however, the Supreme Court eliminated the “watershed rule” exception from the federal test.
10 new rule; (2) the general reliance on the old rule; and (3) the effect on the administration
of justice.’ ” Poole, ___ Mich at ___; slip op at 4, quoting Hampton, 384 Mich at 674.
The Linkletter-Hampton factors weigh against Peeler’s retroactive application.
With respect to the purpose of the new rule, as explained earlier, Peeler concerns the
process of getting to trial, not the fairness of the trial itself. See generally Peeler, 509 Mich
381. Because the rule’s purpose is unrelated to the fairness of a trial, the first Linkletter-
Hampton factor does not favor retroactive application. See Poole, ___ Mich at ___; slip
op at 4. With respect to the general reliance on the old rule, it is undisputed that before
Peeler, prosecutors and judges relied upon the “unchallenged assumption” that the one-
man grand jury law allowed judges to issue criminal indictments. Peeler, 509 Mich at 399.
See also id. at 393-394. The second Linkletter-Hampton factor therefore weighs against
Peeler’s retroactive application. See Poole, ___ Mich at ___; slip op at 4. Finally, although
the exact number of defendants subjected to the errors identified in Peeler is unknown, the
practice appears to have been used with some regularity over many decades in some courts.
Calling into question convictions in numerous cases in which defendants were convicted
following a fair trial under the most stringent beyond-a-reasonable-doubt standard would
therefore hinder unnecessarily the administration of justice in Michigan. For that reason,
the third Linkletter-Hampton factor also weighs against Peeler’s retroactive application.
Thus, the Linkletter-Hampton factors do not support applying Peeler retroactively on
11 IV. CONCLUSION
We hold that a Peeler error does not implicate a circuit court’s subject-matter
jurisdiction and that Peeler does not apply retroactively on collateral review. Accordingly,
we affirm the Court of Appeals’ decision affirming the trial court’s denial of defendant’s
second motion for relief from judgment. However, we vacate the Court of Appeals’
analysis holding that Peeler did not announce a new rule of law.
Elizabeth M. Welch Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Kyra H. Bolden Kimberly A. Thomas
HOOD, J., did not participate because he was on the Court of Appeals panel that issued the decision under review.