Michigan v. Wood (Opinion - Leave Granted)
Annotate this CaseKeith Wood was convicted by jury of jury tampering, for having distributed a pamphlet promoting the concept of jury nullification outside the courthouse at which the pretrial hearing of a man named Andrew Yoder was scheduled to begin. The pamphlet asserted that jurors could vote their conscience, that jurors could not be forced to obey a juror oath, and that a juror had the right to hang a jury if he or she did not agree with other jurors. Defendant handed the pamphlet to two women who told him that they had been summoned to the court for jury selection. The case against Yoder never went to trial because Yoder entered into a plea agreement. After being charged in district court with obstruction of justice, and jury tampering, defendant moved to dismiss both charges, arguing with regard to the jury-tampering charge that the term “juror” in MCL 750.120a(1) did not include people who were summoned for jury duty but never selected or sworn. The district court dismissed the obstruction charge, but denied the motion to dismiss the tampering charge. The circuit court and Court of Appeals affirmed the district court. The Michigan Supreme Court reversed, finding that individuals who were merely summoned for jury duty and have not yet participated in a case were not jurors for purposes of MCL 750.120a(1). Therefore, defendant did not attempt to influence the decision of any “juror” as that term was used in MCL 750.120a(1).