People of Michigan v. Nicolas Lyon

Summary

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