The case involved two defendants who, in 1983, were convicted of armed robbery, assault with intent to commit murder, and felony-firearm after shooting a robbery victim, who survived at the time. More than four years later, after the victim died from complications of the gunshot wounds, the defendants were tried and convicted of felony murder and felony-firearm. The Michigan Supreme Court held that the subsequent prosecutions did not violate double jeopardy under the U.S. or Michigan constitutions, as the victim's later death created a distinct offense not previously prosecuted. However, the court determined that the defendants' prior convictions for armed robbery and assault with intent to murder must be vacated to prevent multiple punishments for the same conduct, with time served credited toward the felony murder sentences.
In Gray v. Morley, an employee sued his employer after suffering serious injuries when thrown from the back of a pickup truck during a work-related drive, claiming the employer's erratic driving amounted to an intentional tort outside the workers' compensation system. The Michigan Supreme Court affirmed summary disposition for the employer, holding that the claim was barred by the exclusive remedy provision of the Worker's Disability Compensation Act. The court reasoned that the statute permits an intentional tort exception only when the employer commits a deliberate act with the specific intent to injure the employee, a standard not met by evidence of prior reckless or game-like driving that did not establish certainty of injury or deliberate targeting in this instance.
This case concerned whether evidence seized during a search of the defendant's home pursuant to a valid warrant should be suppressed due to police officers' violation of the knock-and-announce statute and Fourth Amendment requirements by waiting only eleven seconds before forcing entry. The Michigan Supreme Court held that the evidence was admissible under the inevitable discovery exception to the exclusionary rule because the items would have been found regardless of the premature entry and suppressing them would improperly disadvantage the prosecution. The court further concluded that the state knock-and-announce statute does not reflect legislative intent to require exclusion of evidence for its violation. It therefore reversed the trial court's suppression order and the Court of Appeals affirmance.
The case involved Mary Glover, who was serving parolable life sentences for second-degree murder and assault after a 1976 gas station robbery that resulted in one death. Glover challenged the parole board's denial of parole after a public hearing, arguing that the board failed to provide an adequate written explanation, violated the Open Meetings Act by deciding in private, and that statutory changes to parole review intervals were unconstitutional. The Michigan Supreme Court held that there was no federal or state due process right to a written explanation and that the Open Meetings Act did not apply to the parole board. However, the court affirmed a remand to the board for a more detailed explanation under MCL 791.235(12), reasoning that the statute requires sufficient detail to allow meaningful judicial review of the board's discretionary decision, even without a constitutional mandate.
The case concerned whether the Michigan Supreme Court's prior decision in Profit v. Citizens Ins. Co. of America, requiring offset of social security disability benefits against no-fault work-loss benefits under MCL 500.3109(1), applies retroactively to allow insurers to recover overpayments made before that ruling. The court held that Profit applies retroactively, that insurers possess an equitable common-law right to reimbursement for such overpayments, but only when reimbursement would be fair in light of all circumstances, and that the doctrine of laches does not bar recovery here. This rested on earlier precedents interpreting the offset statute, principles of restitution, and the absence of sufficient detrimental reliance by the defendants.
The consolidated cases Dorris v. Detroit Osteopathic Hospital and Gregory v. Heritage Hospital arose from medical malpractice and related claims in which plaintiffs sought discovery of third-party patient identities and hospital records to support allegations of negligent treatment and inadequate supervision. The Michigan Supreme Court held that the statutory physician-patient privilege under M.C.L. § 600.2157 protects the names of unknown patients from disclosure by hospitals, even in discovery, and that hospitals have a corresponding duty of nondisclosure. It affirmed the Court of Appeals reversal of the order compelling disclosure in Dorris. In Gregory, the Court partially reversed the trial court's discovery and summary disposition rulings, holding that certain investigative materials were not protected but that the plaintiff was required to comply with notice-of-intent and affidavit-of-merit requirements for the malpractice claim, and remanded for further proceedings.
