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People of Michigan v. Steven Jerome Goodman
332763
Mich. Ct. App.
Oct 10, 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: People of Michigan v. Steven Jerome Goodman
Court Name: Michigan Court of Appeals
Date Published: Oct 10, 2017
Docket Number: 332763
Court Abbreviation: Mich. Ct. App.