People of Michigan v. Todd Douglas Robinson
Unknown
Mich. Ct. App.2024Background
- Todd Douglas Robinson was convicted in 2013 of first-degree premeditated murder and possession of a firearm during a felony, stemming from a fatal shooting during a drug deal in 2012.
- Robinson was charged via indictment by a "one-man grand jury" without a preliminary examination, a process later found improper by the Michigan Supreme Court in People v. Peeler.
- Robinson's request for a preliminary examination or to quash the information was denied by the trial court. His first motion for relief from judgment was unsuccessful.
- Following the Supreme Court's Peeler decision, Robinson filed a successive motion for relief from judgment, arguing that his prosecution was void due to the improper indictment process.
- The trial court denied the motion, holding that Peeler was not retroactively applicable, and that even if it were, the error was harmless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Peeler's invalidation of one-man grand jury indictments applies retroactively and voids Robinson's conviction | Robinson: Peeler should apply retroactively, so his indictment and conviction are void for lack of jurisdiction | State: Peeler does not apply retroactively; even if it did, the trial court still had jurisdiction | Peeler did not make a retroactive change in law; improper procedure was harmless and did not deprive jurisdiction |
| Whether the absence of a preliminary examination deprived the circuit court of subject-matter jurisdiction | Robinson: Lack of preliminary exam deprived the court of jurisdiction, making judgment void | State: Circuit courts retain jurisdiction in felony cases regardless of procedural defect | Error did not deprive court of subject-matter jurisdiction; jurisdiction unaffected |
| Whether the improper indictment was a jurisdictional or procedural defect requiring relief | Robinson: Error in charging was jurisdictional, so relief required regardless of prejudice | State: Error was procedural, not jurisdictional; no showing of prejudice or unfair trial | Error is procedural and harmless; no relief warranted |
| Whether Robinson showed actual prejudice or good cause under MCR 6.508(D)(3) for relief from judgment | Robinson: Relief should be granted based on jurisdictional defect (prejudice/good cause not required) | State: No actual prejudice or good cause shown; conviction by jury confirms fair trial | No showing of actual prejudice; conviction by jury supports finding of harmless error |
Key Cases Cited
- People v. Peeler, 509 Mich 381 (improper charging via one-man grand jury and right to preliminary examination)
- People v. Washington, 508 Mich 107 (jurisdictional defects render judgment void ab initio)
- People v. Goecke, 457 Mich 442 (circuit court jurisdiction over felonies not lost by improper information)
- In re Elliott, 315 Mich 662 (filing a void or improper information does not deprive circuit court of jurisdiction)
- People v. Hall, 435 Mich 599 (preliminary examination is not constitutionally required; harmless error doctrine applies)