People v. Breidenbach
489 Mich. 1
| Mich. | 2011Background
- Defendant Breidenbach was charged with indecent exposure as a sexually delinquent person under MCL 750.335a and MCL 767.61a, tried before a single jury with prior sexual offense history admitted.
- Helzer (1978) held mandatory bifurcation: separate juries must hear sexual delinquency charges when joined to a principal offense.
- Trial court granted a new trial based on Helzer after Court of Appeals vacated the conviction; prosecutor sought review, arguing Helzer was wrongly decided.
- Court analyzes whether separate juries are required by MCL 767.61a’s plain language and whether Helzer’s rule should stand.
- Court overrules Helzer to the extent it mandatory bifurcation, holding separate juries are discretionary under Michigan Court Rules; remands to reinstate conviction.
- Concurrences address forfeiture, stare decisis, and policy considerations; majority reinstates conviction and vacates the new-trial order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does MCL 767.61a require separate juries? | Breidenbach argues Helzer mandated bifurcation. | Breidenbach contends the statute does not require separate juries. | Separate juries are not mandatory; discretion allowed. |
| Should Helzer be overruled under stare decisis analysis? | Helzer’s rule should be overruled as impractical and misaligned with the statute. | Helzer remains proper precedent unless forfeited or clearly defective. | Helzer partially overruled; discretion framework replaces mandatory bifurcation. |
| What governs the decision to empanel separate juries when sexual delinquency is charged with another offense? | Helzer’s policy rationale supports automatic bifurcation. | Court rules authorize joinder/severance based on fairness and practicality. | Courts may order separate juries when needed to promote fairness; not required in all cases. |
| Is the appeal waivable or prosecutorially waived due to forfeiture? | N/A (addressed in concurrence); focus on merits. | Defendant forfeited the Helzer issue by not objecting at trial. | Forfeiture arguments acknowledged; majority proceeds on merits regarding Helzer. |
| Should the prior-acts evidence and other doctrines affect the necessity of bifurcation? | Potential prejudice from joined evidence supports bifurcation. | Evidence can be managed with limiting instructions and doctrine of chances. | Evidence rules and limiting instructions mitigate prejudice; bifurcation not universally required. |
Key Cases Cited
- People v Helzer, 404 Mich 410 (1978) (mandatory bifurcation rule for sexual delinquency cases (overruled in part))
- People v Davis, 468 Mich 77 (2003) (evidence and severance principles in Michigan procedure)
- Robinson v Detroit, 462 Mich 439 (2000) (multifactor test for overruling precedent; reliance interests)
- People v Williams, 483 Mich 226 (2009) (doctrine of chances and admissibility of prior acts)
- People v Mardlin, 487 Mich 609 (2010) (application of doctrine of chances in admissibility of other acts)
- Spencer v Texas, 385 US 554 (1967) (no federal constitutional right to bifurcated trials)
- Zafiro v United States, 506 US 534 (1993) (prejudice in joint trials and severance standards)