Michigan Supreme Court
People of Michigan v. James Curtis Beck
July 27, 2022
Summary
The court held that the retrial on the 2016 criminal-sexual-conduct charges violated double-jeopardy protections because the trial court declared a mistrial without adequately investigating the alleged juror misconduct or establishing manifest necessity. It vacated those convictions but denied relief on the 2017 convictions, concluding that the challenged other-acts evidence would have been admissible in a separate trial. The court also found plain error in applying a mandatory minimum sentence to a CSC-I count whose charging document did not allege the defendant's qualifying age, but denied resentencing because the error did not fundamentally affect the fairness of the trial.