People of Michigan v. Tremel Anderson, 501 Mich. 175

Background

Defendant Tremel Anderson was charged with assault with intent to commit murder, carrying a concealed weapon, felonious assault, and felony-firearm after Michael Larkins testified that Anderson pointed a gun at him, attempted to shoot him, and fired additional shots that missed.
Larkins’s testimony was the only evidence presented at the preliminary examination.
The district court magistrate found Larkins not credible based on inconsistencies and demeanor and dismissed the charges for lack of probable cause.
The prosecutor appealed to the circuit court (which denied the appeal without opinion) and the Court of Appeals (which affirmed in a split decision).
The Michigan Supreme Court granted review and addressed whether a magistrate may assess witness credibility at a preliminary examination when determining probable cause.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a magistrate may consider witness credibility at a preliminary examination when deciding probable cause	Magistrate should be limited (per Lemmon standard) and accept testimony unless it is so impeached that it has no probative value or contradicts indisputable physical facts	Magistrate may assess credibility and weigh evidence as trier of fact for preliminary hearing purposes	Court held magistrates must consider all evidence including credibility; Lemmon standard for new-trial motions is inapplicable
Standard for bindover at preliminary examination	Probable cause requires sufficient evidence of elements, but credibility assessment should be constrained	Probable-cause determination permits judgment about witness credibility and weight of evidence	Probable cause = evidence sufficient to cause a person of ordinary prudence and caution to conscientiously entertain a reasonable belief of guilt; magistrate must "determine" this considering totality of evidence
Whether magistrate erred in dismissing based solely on discrediting the sole witness	Prosecutor argued dismissal improper because conflict-of-evidence/ doubts should be left to jury	Magistrate argued sole testimonial evidence was not credible and no other evidence existed to establish probable cause	Court held magistrate did not abuse discretion: articulated principled reasons to find complainant not credible and no other evidence supported bindover
Proper appellate review of magistrate credibility findings	Prosecutor urged limited deference and narrower review	Defendant asserted magistrate’s credibility finding entitled to deference given live-observer advantage	Court reaffirmed abuse-of-discretion standard; appellate courts must defer where outcome is within range of principled outcomes

Key Cases Cited

Gerstein v. Pugh, 420 U.S. 103 (U.S. 1975) (Fourth Amendment requires timely judicial determination of probable cause)
People v. Yost, 468 Mich. 122 (Mich. 2003) (defines probable cause standard for bindover)
People v. Lemmon, 456 Mich. 625 (Mich. 1998) (limits judicial reweighing of credibility on new-trial motions)
People v. Paille #2, 383 Mich. 621 (Mich. 1970) (magistrate has duty to judge weight, competency, and credibility at preliminary exam)
People v. Seewald, 499 Mich. 111 (Mich. 2016) (abuse-of-discretion standard for reviewing magistrate bindover decisions)
People v. King, 412 Mich. 145 (Mich. 1981) (magistrate must examine the whole matter before determining bindover)
Yaner v. People, 34 Mich. 286 (Mich. 1876) (conflict of evidence and reasonable doubt usually left for jury at trial)
People v. Doss, 406 Mich. 90 (Mich. 1979) (preliminary exam not for determining guilt beyond reasonable doubt)
People v. Feeley, 499 Mich. 429 (Mich. 2016) (statutory interpretation principles)
People v. Babcock, 469 Mich. 247 (Mich. 2003) (abuse-of-discretion framework explaining principled-outcomes review)