Michigan v. Beck (Opinion on Application - Partial Affirm)
Annotate this CaseIn 2016, defendant James Beck was charged relating to allegations that he sexually assaulted his minor daughter, TG (first-degree criminal sexual conduct (CSC-I), and three counts of second-degree criminal sexual conduct (CSC-II)). During the jury’s deliberations, one of the jurors notified the trial court that another juror might have done outside research on the case. The trial court polled the jury by written note to find out whether any of the jurors were aware of that research. Two of the jurors responded affirmatively. The trial court rejected the parties’ requests to either replace the jurors or to allow them to remain seated, and determined that the entire jury was tainted and declared a mistrial. In 2017, while awaiting retrial, defendant was accused of sexually assaulting CS, the minor friend of one of his children, and was charged with two counts of CSC-I and one count of CSC-II. The 2016 charges and the 2017 charges were jointly tried in a second trial, and defendant was found guilty of all charges. The issues presented on appeal to the Michigan Supreme Court were: (1) whether the retrial of defendant’s original charges were barred by double jeopardy; (2) if barred, whether vacating those conviction would entitle defendant to any relief with respect to his remaining convictions; and (3) whether the trial court erred in imposing a mandatory sentence of 25 years for defendant’s CSC-I conviction when the information did not state the charge carried this minimum sentence. The Supreme Court found the trial court abused its discretion by declaring a mistrial without an inquiry sufficient to support a finding of manifest necessity, and vacated those convictions. The Court found defendant did not demonstrate he was entitled to any relief regarding the other convictions. Finally, the Court concluded the trial court committed plain error in imposing the mandatory 25-year minimum sentence because it was not charged, and defendant was not entitled to relief because this error did not result in a fundamentally unfair trial.
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