People of Michigan v. Paul David Domanski, 328154

Defendant Paul Domanski was convicted by a jury of three counts of first‑degree criminal sexual conduct and three counts of second‑degree criminal sexual conduct for repeated sexual touching and digital penetration of a child under 13 while he lived with the child and her mother.
After the mother confronted Domanski at a gas station in Ohio, Sylvania PD Sgt. Pack spoke to him on‑scene; Domanski admitted misconduct but was not arrested there. Pittsfield Twp. Sgt. Hohner later read Miranda warnings, obtained a signed waiver, and recorded Domanski admitting digital penetration and other touching; the videotape was played at trial.
Domanski testified at trial that he had falsely confessed earlier because he felt hopeless and wanted to please investigators; he denied committing the acts.
Pretrial voir dire included nine off‑the‑record bench discussions with the court and counsel about specific prospective jurors; portions of the transcript were missing due to clerk error. Defense counsel accepted the empaneled jury and had remaining peremptory challenges.
The trial court admitted the on‑scene and post‑Miranda statements, denied a motion to substitute counsel (defendant never invoked self‑representation), and considered statutory sentencing constraints when imposing lengthy concurrent prison terms. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of record regarding off‑the‑record voir dire	Surviving record allows review; defense waived objection by accepting jury	Missing bench‑conference transcript impeded appellate review of juror responses	Court: No relief; defense waived error by expressing satisfaction with jury and retaining peremptories
Miranda suppression of statements	On‑scene statements were noncustodial; later statements followed proper Miranda warnings and waiver	Initial uncautioned admission to Sgt. Pack tainted later custodial confession	Court: No Miranda violation; on‑scene questioning was noncustodial and later waiver was valid
Right to counsel / self‑representation	Trial court properly denied substitution; defendant never requested self‑representation	Defendant contends denial to represent himself lacked analysis	Court: Meritless; defendant requested new counsel not to self‑represent and gave no substantial reason to replace appointed counsel
Sentencing / consideration of guidelines	Trial court referenced guidelines and statutory mandatory minima when sentencing	Defendant argues court ignored guidelines and relied on irrelevant comments	Court: No error; court properly applied sentencing law and mandatory minimum under statute rather than the guidelines range

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes warnings required before custodial interrogation)
People v. Cress, 468 Mich. 678 (Mich. 2003) (standard of review for denial of new trial—abuse of discretion)
People v. Kowalski, 492 Mich. 106 (Mich. 2012) (abuse‑of‑discretion framework explained)
People v. Coomer, 245 Mich. App. 206 (Mich. Ct. App. 2001) (review standards for factual findings and custodial interrogation analysis)
People v. Herndon, 246 Mich. App. 371 (Mich. Ct. App. 2001) (de novo review of custody determination for Miranda purposes)