People v. Wilson
496 Mich. 91
| Mich. | 2014Background
- Defendant was tried and convicted of first-degree felony murder (predicated on first-degree home invasion) and several other offenses; acquitted of first-degree premeditated murder and first-degree home invasion.
- Court of Appeals reversed the convictions (trial error: denial of self-representation) and remanded for retrial; acquittals (including home invasion) remained intact.
- Prosecution sought to refile felony-murder charge on retrial; defendant moved to dismiss under Double Jeopardy / collateral estoppel because home invasion (the only predicate felony) had been acquitted.
- Trial court granted dismissal; Court of Appeals reversed, relying on precedent permitting inconsistent verdicts (Powell/Dunn).
- Michigan Supreme Court majority held collateral estoppel (Ashe/Yeager strand of Double Jeopardy) bars retrial on felony murder because the prior acquittal of the predicate felony precludes relitigation of that element.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Wilson) | Held |
|---|---|---|---|
| Whether Double Jeopardy (collateral estoppel) bars retrial of felony-murder charge when the only predicate felony was previously acquitted but the felony-murder conviction was later reversed on appeal | Inconsistent jury verdicts (conviction + acquittal) mean collateral estoppel is inapplicable; Powell/Dunn allow giving effect to inconsistent jury verdicts and permit retrial after reversal | The prior acquittal of the predicate offense is a final adjudication that collateral estoppel (Ashe/Yeager) makes binding; retrial on felony-murder would relitigate an issue already decided in defendant’s favor | Held for defendant: collateral estoppel strand of Double Jeopardy bars retrial of felony murder because the acquittal of the only predicate felony precludes relitigation of that element |
Key Cases Cited
- Ashe v. Swenson, 397 U.S. 436 (1970) (establishes collateral estoppel as part of Fifth Amendment double jeopardy protection)
- Yeager v. United States, 557 U.S. 110 (2009) (acquittals have preclusive effect; hung counts are legal nonevents for issue-preclusion)
- United States v. Powell, 469 U.S. 57 (1984) (inconsistent jury verdicts may stand; collateral estoppel is impractical where verdicts are inconsistent)
- Dunn v. United States, 284 U.S. 390 (1932) (verdicts may be inconsistent; courts should not inquire into jury compromise/mistake)
- Burks v. United States, 437 U.S. 1 (1978) (appellate reversal for trial error does not imply innocence; retrial is ordinarily permitted)
- Ball v. United States, 163 U.S. 662 (1896) (an acquittal is final and bars subsequent prosecution)
- Fong Foo v. United States, 369 U.S. 141 (1962) (acquittal is an absolute bar to retrial even if based on error)
- Boston Municipal Court Justices v. Lydon, 466 U.S. 294 (1984) (acquittals, not convictions, terminate initial jeopardy; double jeopardy concerns arise only on second trial)