People of Michigan v. Vickie Rose Hamlin, 321352

Defendants Vickie Hamlin and Barbara Carter were convicted in Ingham Circuit Court; this Court affirmed in an unpublished opinion and the Michigan Supreme Court remanded for reconsideration in light of People v Stevens.
At trial the judge questioned defendant Carter about whether a police officer had "asked" versus "commanded" her to leave, probing the distinction and appearing to challenge Carter’s testimony.
Defendants argued the judge’s questioning demonstrated judicial partiality that could have improperly influenced the jury.
The jury later asked for clarification during deliberations on what constituted a "lawful command."
The trial court repeatedly instructed the jury that its questions and comments were not evidence and that the court did not intend to express an opinion; these instructions were given at the start of trial, during trial, and in the final charge.
On remand the Court of Appeals applied the Stevens framework and concluded that, under the totality of the circumstances and because of the repeated curative instructions, the judge’s conduct did not deprive defendants of a fair trial and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial judge’s questioning pierced the veil of judicial impartiality	The court’s questioning was appropriate clarification and did not create appearance of bias	The judge’s tone and focused questioning of Carter evidenced partiality that could influence the jury	Court: Questions sought clarification and were limited; tone was concerning at points but not enough to show impermissible bias
Whether curative instructions cured any potential prejudice from the judge’s conduct	The multiple instructions (opening, during trial, final charge) adequately informed jurors not to treat judicial comments as evidence	The instructions could not cure substantial bias created by the judge’s questioning	Court: Unlike Stevens (single end-of-trial instruction), the frequent and specific curative instructions here weigh heavily against finding the judge pierced the veil of impartiality; prejudice was cured

People v Stevens, 498 Mich 162 (Mich. 2015) (framework for evaluating when judicial conduct pierces judicial impartiality and role of curative instructions)
People v Graves, 458 Mich 476 (Mich. 1998) (jurors presumed to follow judicial instructions)