People v. Harris
495 Mich. 120
| Mich. | 2014Background
- Harris was convicted by jury in Saginaw Circuit Court of extortion and related firearm offenses for threatening mechanic Neal to resume work or return money during rainfall while Harris was armed.
- The extortion charge hinged on the ‘against his will’ prong of MCL 750.213; the key issue was whether the compelled act had to be of serious consequence.
- Michigan Court of Appeals relied on People v Fobb and People v Hubbard to require serious consequences for the compelled act.
- The Supreme Court granted leave to determine the proper scope of extortion under MCL 750.213 and sufficiency of the evidence.
- The Court overruled Fobb and Hubbard, clarifying that the statute’s plain language requires a malicious threat to compel any act against the victim’s will, regardless of the act’s seriousness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether extortion requires the compelled act be of serious consequence | Harris—Fobb/Hubbard require serious consequence | Harris—statutory language covers any act | No; plain language does not require seriousness; overrule Fobb/Hubbard |
| Whether the extortion statute provides adequate notice and guidance | Statutory language is vague and overbroad | Malice requirement provides explicit standard | Statute provides sufficient notice and guidance; vagueness rejected |
| Whether there was sufficient evidence to convict extortion | Evidence showed malicious threat while armed | Threat may not compel an act with serious consequence | There was sufficient evidence: malicious threat to injure and intent to compel an act against Neal’s will |
| Whether Hubbard/Fobb overruled; impact on conviction validity | Precedent controlled conduct scope | Hubbard/Fobb limited statute to serious acts | Overruled; extortion conviction affirmed based on plain statute text |
| Role of malice in proving extortion | Malice not required beyond threat | Malice essential to show wrongful act | Malice defined as intent to commit a wrongful act or reckless disregard; applicable to proof of extortion |
Key Cases Cited
- People v Fobb, 145 Mich. App. 786, 378 N.W.2d 600 (1985) (Mich. Ct. App. 1985) (held act must be of serious consequence to sustain extortion under MCL 750.213)
- People v Hubbard (After Remand), 217 Mich. App. 459, 552 N.W.2d 493 (1996) (Mich. Ct. App. 1996) (adopted Fobb’s serious-consequence limitation; later overruled)
- People v Tombs, 472 Mich. 446, 697 N.W.2d 494 (2005) (Mich. 2005) (inference of criminal intent where statutory language lacks explicit mens rea)
- People v Boomer, 250 Mich. App. 534, 655 N.W.2d 255 (2002) (Mich. Ct. App. 2002) (noted vagueness concerns when statute lacks guidance; used for notice analysis)
- Kolender v. Lawson, 461 U.S. 352, 103 S. Ct. 1855, 75 L. Ed. 2d 928 (1983) (U.S. 1983) (established need for minimal guidelines to prevent arbitrary enforcement)