Michigan Supreme Court

People of Michigan v. Nicolas Lyon

June 28, 2022

Summary

The Court held that defendants charged through a one-man grand-jury proceeding are entitled to a preliminary examination before trial because the governing statutes require such cases to proceed like cases initiated by formal complaint. It also held that those statutes authorize investigation, subpoenas, and arrest warrants but do not authorize a judge acting as a one-man grand jury to issue an indictment initiating a prosecution. The Court therefore reversed the orders denying preliminary examinations and the motion to dismiss, and remanded for further proceedings.