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People v. Frank

Supreme Court of Michigan
Jan 24, 2008
480 Mich. 1035 (Mich. 2008)

Opinion

No. 134993.

January 24, 2008.

Court of Appeals No. 271046.


Summary Dispositions January 24, 2008.

Pursuant to MCR 7.302(G)(1), in lieu of granting leave to appeal, we reverse the judgment of the Court of Appeals and we remand this case to the 50th District Court for a determination whether the evidence presented at the preliminary examination was sufficient, by a preponderance of the evidence, to establish the corpus of the crime charged in the absence of the statement the defendant made to the police. People v Konrad, 449 Mich 263, 269-270 (1995) (a defendant's confession may not be admitted unless there is direct or circumstantial evidence independent of the confession establishing [].] the occurrence of the specific injury and [2] some criminal agency as the source of the injury). The Court of Appeals erred in ruling that the defendant had waived the right to claim error in the district court's use of his statement to the police by supposedly stipulating to the admission of the statement. The Court of Appeals further erred by independently determining that the evidence presented at the preliminary examination was sufficient to create probable cause apart from defendant's statement, when such a determination was not made by either the district court or the Oakland Circuit Court.

I would deny leave to appeal.


Summaries of

People v. Frank

Supreme Court of Michigan
Jan 24, 2008
480 Mich. 1035 (Mich. 2008)
Case details for

People v. Frank

Case Details

Full title:PEOPLE OF THE STATE OF MICHIGAN, Plaintiff-Appellee, v. FRANK STEPHENS…

Court:Supreme Court of Michigan

Date published: Jan 24, 2008

Citations

480 Mich. 1035 (Mich. 2008)