PEOPLE OF MI V MICHAEL RIMSON
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STATE OF MICHIGAN
COURT OF APPEALS
PEOPLE OF THE STATE OF MICHIGAN,
UNPUBLISHED
July 3, 2001
Plaintiff-Appellee,
v
No. 221708
Wayne Circuit Court
Criminal Division
LC No. 98-008139
MICHAEL RIMSON,
Defendant-Appellant.
Before: Sawyer, P.J., and Griffin and O’Connell, JJ.
PER CURIAM.
Defendant was convicted by a jury of first-degree felony murder, MCL 750.316, in the
screwdriver-stabbing death of decedent, Chenguang Wang, a researcher at Wayne State
University. Defendant was sentenced to a mandatory term of life imprisonment. He appeals as
of right. We affirm.
First, defendant argues that, under the corpus delicti rule, because his own statements
provided the only evidence of the underlying felony of larceny, there was insufficient evidence to
support his conviction for felony murder. The purpose of the corpus delicti rule is to guard
against convictions for a crime when none was committed by requiring a showing, independent
of an accused’s statement, that a crime has been committed. People v Emerson (After Remand),
203 Mich App 345, 347; 512 NW2d 3 (1994). As defendant acknowledges, the corpus delicti
rule is satisfied in prosecutions of first-degree felony murder by showing that a death has
occurred as a result of some criminal agency. Id., citing People v Hughey, 186 Mich App 585,
589; 464 NW2d 914 (1990). Here, there was evidence independent of defendant’s confession
that Wang was killed by a stabbing wound to his neck, fully satisfying the corpus delicti rule.
We are bound by the decisions in Emerson and Hughey, MCR 7.215(I)(1), and decline
defendant’s suggestion that we reject their interpretation of the corpus delicti rule.
Defendant also argues that the jury was improperly instructed because, although the trial
court instructed on reasonable doubt and on the elements of the possible verdicts, it did not
specifically state that each element of the charged offense must be proven beyond a reasonable
doubt. In addition to its oral instructions, however, the trial court sent a copy of the jury
instructions into the jury room with the jurors, and those instructions specifically stated that “the
prosecutor must prove each of the following elements beyond a reasonable doubt.” Considered
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as a whole, the instructions fairly presented the issues for trial and sufficiently protected
defendant’s rights. People v Canales, 243 Mich App 571, 574; 624 NW2d 439 (2000).
Affirmed.
/s/ David H. Sawyer
/s/ Richard Allen Griffin
/s/ Peter D. O’Connell
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