People of Michigan v. Randy Henry Beasley
330469
| Mich. Ct. App. | Oct 13, 2016Background
- Defendant Randy Beasley, a prisoner at Baraga Maximum Security Prison, was tried by jury and convicted of assaulting a prison employee (MCL 750.197c) and sentenced to 2–5 years consecutive to existing terms.
- The trial was held on prison grounds in a room provided by the warden rather than in the county courthouse; the court had notified parties of the prison location about three months before trial.
- Defense counsel did not object to the trial location at any pretrial hearings and affirmatively told the court before voir dire that he had no additional matters to address; counsel proceeded with voir dire and trial without raising the venue issue.
- The prosecution introduced strong evidence, including partial prison surveillance video and testimony that defendant attempted to head-butt, spit, kick, bite, resist restraints, and required a chemical agent to be subdued.
- On appeal, defendant argued that holding the trial at the prison violated his due-process right to be presumed innocent and analogized the setting to impermissible courtroom shackling; he raised the issue for the first time on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether holding the jury trial at the prison violated defendant's due-process presumption-of-innocence right | State: defendant forfeited or waived the objection by not timely objecting; trial location followed court administrative order and jurors were vetted; instructions mitigated prejudice | Beasley: trial at prison unconstitutionally prejudiced jurors against an incarcerated defendant, analogous to visible shackling; no finding of special danger justified prison venue | Court: waived/forfeited; even under plain-error review, no reversible error—overwhelming evidence and juror vetting/instructions prevented serious effect on fairness |
Key Cases Cited
- People v. Riley, 465 Mich. 442 (explains waiver versus forfeiture and when appellate relief is available)
- People v. Carter, 462 Mich. 206 (affirmative approval of court action constitutes waiver)
- People v. Vaughn, 491 Mich. 642 (plain-error test for forfeited constitutional claims)
- People v. Mahone, 294 Mich. App. 208 (jurors are presumed to follow jury instructions)