People of Michigan v. Stephen Matthew Butka

Summary

The Michigan Supreme Court held that an application to set aside a conviction requires separate findings that the applicant’s postconviction circumstances and behavior warrant relief and that setting aside the conviction is consistent with the public welfare. It held that public welfare concerns the broader community and cannot be determined solely from the continuing impact on the victims or another limited class of individuals. Because the trial court found that defendant’s postconviction conduct favored relief and relied only on the victims’ continuing emotional distress to deny the application, the Court reversed and directed entry of an order setting aside the conviction.