285 N.W.2d 284 (Mich. 1979), 59843, People v. Hampton
|Docket Nº:||Docket No. 59843.|
|Citation:||285 N.W.2d 284, 407 Mich. 354|
|Opinion Judge:||COLEMAN, Chief Justice.|
|Party Name:||The PEOPLE of the State of Michigan, Plaintiff-Appellant, v. Wayne HAMPTON, Defendant-Appellee.|
|Attorney:||[407 Mich. 364] William L. Cahalan, Pros. Atty., Edward Reilly Wilson, Principal Atty., Appeals, Timothy A. Baughman, Asst. Pros. Atty., Detroit, for plaintiff-appellant. LeRoy W. Daggs, Detroit, for defendant-appellee.|
|Case Date:||November 26, 1979|
|Court:||Supreme Court of Michigan|
Argued Dec. 6, 1978.
Defendant and a codefendant, Lewis Griffin, were charged with two counts of first-degree murder (premeditated and felony murder), M.C.L. § 750.316; M.S.A. § 28.548, resulting from the fatal shooting of Edgar Coleman, Jr. At their trial, defendant made a motion for a directed verdict of acquittal at the conclusion of the people's case. The motion was denied after the judge said that the prosecution had presented evidence on each element of the offense. The motion was renewed at the close of all the proofs and the trial judge reserved his ruling on this motion until after the jury returned a verdict. After the jury found defendant guilty of second-degree murder on both counts, M.C.L. § 750.317; M.S.A. § 28.549, the judge ordered that the verdict be set aside and ordered a new trial. The prosecutor sought leave to appeal in the Court of Appeals but leave was denied. The prosecutor applied for leave to appeal in this Court which was granted and limited to the issue of: "Whether, under the circumstances of this case, the trial court invaded the province of the jury when he granted the defendant's motion for directed verdict after the jury had returned a verdict finding the defendant guilty." 1
On appeal, the prosecutor claims that the trial [407 Mich. 365] judge erred in directing a verdict of acquittal. He claims that the judge erred by employing an improper standard in ruling on the motion, by failing to view the evidence presented by the prosecution, and all reasonable inferences therefrom, in a light most favorable to the prosecution, by considering evidence presented by the defendant and by allowing an inaccurate view of the possible punishment to affect his decision. 2 The prosecutor argues that the standard to be applied in determining whether a motion for a directed verdict should be granted is whether there is Any evidence on each material element of the offense and that questions of the sufficiency of the evidence are for the jury unless there is no evidence at all upon a material point, see People v. Garcia, 398 Mich. 250, 247 N.W.2d 547 (1976); People v. Johnson, 397 Mich. 686, 246 N.W.2d 836 (1976); People v. Abernathy, 253 Mich. 583, 235 N.W. 261 (1931); People v. Eaton, 59 Mich. 559, 26 N.W. 702 (1886); People v. Miller, 78 Mich.App. 336, 259 N.W.2d 877 (1977); People v. Maliskey, 77 Mich.App. 444, 258 N.W.2d 512 (1977). Defendant contends that the proper standard for ruling on a motion for a directed verdict is whether the evidence is sufficient to justify a reasonable person in concluding that defendant is guilty beyond a reasonable doubt, see People v. Edgar, 75 Mich.App. 467, 255 N.W.2d 648 (1977); People v. Royal, 62 Mich.App. 756, 233 N.W.2d 860 (1975).
Recognizing that the reported opinions of the appellate courts of this state contain different and [407 Mich. 366] sometimes conflicting statements of the standards for directed verdicts, we granted leave to appeal in this case to resolve and settle the significant jurisprudential issue of what is the proper standard to be applied in passing on motions for directed verdicts in criminal cases. However, the resolution of this issue is now controlled by the rationale underlying the decision in Jackson v. Virginia, --- U.S. ----, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979).
Jackson held that a Federal habeas corpus court in determining whether a state conviction was based on sufficient evidence, must consider not whether there was any evidence to support the conviction but whether there was sufficient evidence to justify a rational trier of fact in finding guilt beyond a reasonable doubt.
In explaining the constitutional considerations underlying the decision in Jackson the Court stated:
"In short, Winship (In re Winship, 397 U.S. 358, 90 S.Ct. 1068, 25 L.Ed.2d 368) presupposes as an essential of the due process guaranteed by the Fourteenth Amendment that no person shall be made to suffer the onus of a criminal conviction except upon sufficient proof defined as evidence necessary to convince a trier of fact beyond a reasonable doubt of the existence of every element of the offense.
"(T)he federal courts of appeals have generally assumed that so long as the reasonable doubt instruction has been given at trial, the no-evidence doctrine of Thompson v. Louisville (362 U.S. 199, 80 S.Ct. 624, 4 L.Ed.2d 564) remains the appropriate guide for a federal habeas corpus court to apply in assessing a state prisoner's challenge to his conviction as founded upon insufficient evidence. We cannot agree.
"The Winship doctrine requires more than simply a trial ritual. A doctrine establishing so fundamental a [407 Mich. 367] substantive constitutional standard must also require that the factfinder will rationally apply that standard to the facts in evidence. A 'reasonable doubt,' at a minimum, is one based upon 'reason.' Yet a properly instructed jury may occasionally convict even when it can be said that no rational trier of fact could find guilt beyond a reasonable doubt, and the same may be said of a trial judge sitting as jury. In a federal trial, such an occurrence has traditionally been deemed to require reversal of the conviction.
"Under Winship, which established proof beyond a reasonable doubt as an essential of Fourteenth Amendment due process, it follows that when such a conviction occurs in a state trial, it cannot constitutionally stand." (Citations omitted.)
Jackson, supra, at ----, 99 S.Ct., at 2788-2789.
In rejecting the any evidence test, the Court focused on the differences between the concepts of relevancy and sufficiency of the evidence. Under MRE 402, all relevant evidence is admissible unless otherwise excluded. Relevant evidence is defined as evidence having any tendency to make the existence of any fact that is of consequence more probable or less probable than it would be without the evidence, MRE 401. The test of relevancy is designed to determine whether a single piece of evidence is of such significant import that it warrants being considered in a case. The standards for admissibility are designed to permit the introduction of all relevant evidence, not otherwise excluded, on the theory that it is best to have as much useful information as possible in making these types of decisions, Turnbull v. Richardson, 69 Mich. 400, 416, 37 N.W. 499 (1888).
The concept of sufficiency, on the other hand, is designed to determine whether all the evidence, considered as a whole, justifies submitting the case to the trier of fact or requires a judgment as a matter of law. This is in contrast to the standards [407 Mich. 368] for relevancy which usually focus on one particular piece of evidence. The fact that some evidence is introduced does not necessarily mean that the evidence is sufficient to raise a jury issue. Because there is no requirement that the evidence be sufficient to support a conviction to be admissible, it does not necessarily follow that merely because some evidence is admitted, the evidence is sufficient to raise a jury issue. In quantitative terms, the fact that a piece of evidence has some tendency to make the existence of a fact more probable, or less probable, does not necessarily mean that the evidence would justify a reasonable juror in reasonably concluding the existence of that fact beyond a reasonable doubt.
Due process requires that the prosecutor introduce sufficient evidence which could justify a trier of fact in reasonably concluding that defendant is guilty beyond a reasonable doubt before a defendant can be convicted of a criminal offense, see, Jackson, supra. If sufficient evidence is not introduced, a directed verdict or judgment of acquittal should be entered. The statements in Johnson, supra; Abernathy, supra; Eaton, supra, to the effect that a trial judge should direct a verdict only where there is no evidence on a material element of the offense are specifically disapproved.
In summary, the trial judge when ruling on a motion for a directed verdict of acquittal must consider the evidence presented by the prosecution up to the time the motion is made, Garcia, supra, view that evidence in a light most favorable to the prosecution, People v. Vail, 393 Mich. 460, 463, 227 N.W.2d 535 (1975), and determine whether a rational trier of fact could have found that the essential elements of the crime were proven beyond a reasonable doubt, Jackson, supra, at ----, 99 S.Ct., at 2789.
[407 Mich. 369]
However, the standards governing directed verdicts do not require that the jury's verdict of guilty be reinstated. From the facts as they have evolved, we find that the trial judge did not direct a verdict of acquittal. He set aside the jury's verdict and ordered a new trial. Although this ruling was made following arguments on defendant's motion for a directed verdict, the judge actually ordered a new trial and did not direct a verdict. 3 The trial judge's order provided:
"Defendant having moved for a directed verdict at the close of the prosecution's proofs, and that motion having been denied, the court ruling that the prosecution had presented some evidence on all the elements of the offense; and that motion having been renewed at the close of all proofs, and decision reserved by the court until after return of the verdict, and the jury having returned verdicts of guilty of second-degree murder against defendant; this court...
To continue readingFREE SIGN UP