By Ben Solis
Gongwer News Service
The Court of Claims dismissed a constitutional challenge to the state’s carjacking statute on improper grounds, depriving the plaintiff of a chance to respond, but reached the correct conclusion to throw out the case, a unanimous Court of Appeals panel ruled last Thursday.
In an unpublished per curiam opinion released last Friday, the panel in Quinn v. Michigan (COA Docket No. 362356) affirmed the Court of Claims, though it disagreed with its reasoning, as it improperly applied two doctrines to dismiss the case.
The panel consisted of Judge Noah Hood, Judge Colleen O’Brien, and Judge Allie Greenleaf Maldonado.
The case centered around the plaintiff’s carjacking conviction in 2008, where he and two others attempted to cash a stolen check at a bank, failed to do so, and drove off in a getaway car. The plaintiff crashed that vehicle into a police cruiser, fled on foot and forcibly removed a person from another vehicle and drove off. The plaintiff then crashed the second vehicle into a motorcyclist.
In all, the spree left several people with various physical and psychological injuries.
Prosecutors charged the plaintiff with several crimes, including carjacking. He pleaded no contest so the trial court would cap his minimum sentence at 25 years in prison with a fourth-offense habitual
offender notice. The trial court, however, noted that an evaluation of the offenses under applicable case law would be significantly more lenient than what was appropriate for the circumstance, but ended up offering the agreement because out-of-state witnesses and victims were involved and would have been inconvenienced if a trial commenced.
The trial court sentenced the plaintiff to a fourth-offense sentence of 25 to 75 years in prison for the carjacking charge, specifically.
He sought leave to appeal the plea-based conviction. The Court of Appeals case record shows that he appealed the conviction a total of five times.
The plaintiff filed his complaint challenging the carjacking statute in early 2022. The statute provides that the crime is a felony punishable by imprisonment for a term of years of life. He argued that the carjacking statute treats unarmed carjackers more harshly than other unarmed robbers, which he deemed unconstitutional cruel and unusual punishment, a violation of due process rights and a violation of equal protection.
The Court of Claims dismissed the case, but on grounds never raised by the defendant – the people of Michigan – ruling that the claim was barred by collateral estoppel and res judicata. That means, if there is a final judgment made on the merits, another plaintiff cannot relitigate the same matter for the same cause of action, according to Cornell Law.
In that ruling, the Court of Claims also commented that the plaintiff had failed to state a claim because he offered no case law and limited argument in support of his carjacking challenge, failing to overcome the presumption that the statute was constitutional.
Upon appeal, before Hood, O’Brien, and Maldonado, the panel ruled that the Court of Claims incorrectly relied on the doctrine of res judicata and collateral estoppel because they were not raised by either party and because the plaintiff did not have a chance to respond to those arguments.
That said, the court ultimately reached the correct outcome and properly disposed the challenge to the carjacking statute.
“It would not be unreasonable for the Legislature to have concluded that automobiles are of such great importance to the citizens of Michigan, and their theft sufficiently destructive to individuals and to society above and beyond harms caused by any other sort of forcible larceny, to warrant ‘special treatment,’ or a harsher penalty,” the panel wrote. “We can question the wisdom of that conclusion, but it satisfies the requirement of a nonarbitrary, rational relationship to the legislative goal. Quinn, therefore, fails to establish that there is no rational basis for imposing a harsher penalty for carjacking than for unarmed robbery.”
Gongwer News Service
The Court of Claims dismissed a constitutional challenge to the state’s carjacking statute on improper grounds, depriving the plaintiff of a chance to respond, but reached the correct conclusion to throw out the case, a unanimous Court of Appeals panel ruled last Thursday.
In an unpublished per curiam opinion released last Friday, the panel in Quinn v. Michigan (COA Docket No. 362356) affirmed the Court of Claims, though it disagreed with its reasoning, as it improperly applied two doctrines to dismiss the case.
The panel consisted of Judge Noah Hood, Judge Colleen O’Brien, and Judge Allie Greenleaf Maldonado.
The case centered around the plaintiff’s carjacking conviction in 2008, where he and two others attempted to cash a stolen check at a bank, failed to do so, and drove off in a getaway car. The plaintiff crashed that vehicle into a police cruiser, fled on foot and forcibly removed a person from another vehicle and drove off. The plaintiff then crashed the second vehicle into a motorcyclist.
In all, the spree left several people with various physical and psychological injuries.
Prosecutors charged the plaintiff with several crimes, including carjacking. He pleaded no contest so the trial court would cap his minimum sentence at 25 years in prison with a fourth-offense habitual
offender notice. The trial court, however, noted that an evaluation of the offenses under applicable case law would be significantly more lenient than what was appropriate for the circumstance, but ended up offering the agreement because out-of-state witnesses and victims were involved and would have been inconvenienced if a trial commenced.
The trial court sentenced the plaintiff to a fourth-offense sentence of 25 to 75 years in prison for the carjacking charge, specifically.
He sought leave to appeal the plea-based conviction. The Court of Appeals case record shows that he appealed the conviction a total of five times.
The plaintiff filed his complaint challenging the carjacking statute in early 2022. The statute provides that the crime is a felony punishable by imprisonment for a term of years of life. He argued that the carjacking statute treats unarmed carjackers more harshly than other unarmed robbers, which he deemed unconstitutional cruel and unusual punishment, a violation of due process rights and a violation of equal protection.
The Court of Claims dismissed the case, but on grounds never raised by the defendant – the people of Michigan – ruling that the claim was barred by collateral estoppel and res judicata. That means, if there is a final judgment made on the merits, another plaintiff cannot relitigate the same matter for the same cause of action, according to Cornell Law.
In that ruling, the Court of Claims also commented that the plaintiff had failed to state a claim because he offered no case law and limited argument in support of his carjacking challenge, failing to overcome the presumption that the statute was constitutional.
Upon appeal, before Hood, O’Brien, and Maldonado, the panel ruled that the Court of Claims incorrectly relied on the doctrine of res judicata and collateral estoppel because they were not raised by either party and because the plaintiff did not have a chance to respond to those arguments.
That said, the court ultimately reached the correct outcome and properly disposed the challenge to the carjacking statute.
“It would not be unreasonable for the Legislature to have concluded that automobiles are of such great importance to the citizens of Michigan, and their theft sufficiently destructive to individuals and to society above and beyond harms caused by any other sort of forcible larceny, to warrant ‘special treatment,’ or a harsher penalty,” the panel wrote. “We can question the wisdom of that conclusion, but it satisfies the requirement of a nonarbitrary, rational relationship to the legislative goal. Quinn, therefore, fails to establish that there is no rational basis for imposing a harsher penalty for carjacking than for unarmed robbery.”
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