People of Michigan v. Steven Jerome Goodman
332763
Mich. Ct. App.Oct 10, 2017Background
- Victim Chantel Carrington disappeared after attending a June 6, 2015 party; her body was found July 14 in advanced decomposition at an abandoned house, killed by a gunshot to the chest.
- Witnesses (Crenshaw and Plummer) saw defendant Steven Goodman drive away with Carrington around 9:00–10:00 p.m. on June 6, with Carrington in the passenger seat.
- Cell-phone tower records placed defendant’s phone within about a one-mile radius of where the body was found at 11:52 p.m. on June 6.
- Defendant told police and Carrington’s sister he had not seen her since earlier that day and claimed to be home that night; he also referred to a “nasty” violent relationship with Carrington.
- A few days after the disappearance defendant allegedly tried to sell two guns.
- Procedural posture: District court bound defendant over; the circuit court quashed the information for insufficiency of evidence; the Court of Appeals reversed and remanded for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there probable cause that Goodman was Carrington’s killer (identity)? | Witness sightings, phone location data, lies to police/sister and post-disappearance conduct support probable cause. | Evidence is insufficient to link Goodman to the murder. | Yes — probable cause supported bindover. |
| Was there probable cause that the killing was premeditated? | Circumstances (prior violent relationship, secluded transport, shot to chest aimed at vital organ, post-crime deception) support inference of premeditation. | Insufficient proof of deliberation/premeditation. | Yes — factors permitted an inference of premeditation for bindover. |
| Was the district court’s bindover properly quashed by the circuit court? | Bindover was proper because probable cause existed on identity and premeditation. | Circuit court erred in quashing for insufficiency. | Circuit court erred; reversal and remand for trial. |
| Do weapons-possession charges require separate bindover analysis here? | Not contested at the quash stage by defendant; bindover for murder supports moving forward. | Not raised as a basis to quash. | Court did not decide the propriety of bindover on weapons counts. |
Key Cases Cited
- People v. Grayer, 235 Mich App 737 (discussing standard of review for quash/bindover)
- People v. Kowalski, 492 Mich 106 (abuse of discretion defined as outside principled outcomes)
- People v. Perkins, 468 Mich 448 (preliminary exam requires probable cause, not proof beyond a reasonable doubt)
- People v. Yamat, 475 Mich 49 (probable cause defined for preliminary exam)
- People v. Brown, 239 Mich App 735 (circumstantial evidence and inferences can support bindover)
- People v. Anderson, 209 Mich App 527 (factors to infer premeditation/deliberation)
- People v. Kvam, 160 Mich App 189 (use of inherently dangerous instrument aimed at vital organs can support premeditation)
