Due process; Waived issue; Bindover on a human trafficking charge & the corresponding count of using a computer to commit a crime; Whether defendant benefited financially; MCL 750.462d(b); MCL 750.462f(1)(b); MCL 750.159f(a); The corpus delicti rule; People v Schumacher; People v Williams; Right to confrontation

The court held that the district court did not abuse its discretion by finding that the prosecution presented sufficient evidence to bind defendant over on a human trafficking charge and using a computer to commit a crime. His argument on appeal was that the prosecution did not present sufficient evidence showing that defendant benefited financially as required by MCL 750.462d(b). His wife testified that he “told her that he received money in exchange for posting the sex videos on the Internet. This evidence was sufficient to support a finding of probable cause” that he benefited financially. But he argued that the testimony by his wife as to the financial benefit he received was admitted in violation of the corpus delicti rule. His “wife testified that defendant told her that he received money for uploading the videos depicting sex acts.” Establishing that he “received money to upload the pornographic videos was not alone sufficient to prove that defendant was guilty of human trafficking—far from it.” The prosecution also relied on the videos and the “wife’s testimony that defendant pressured her to engage in sexual activity with other men and threatened to withhold financial support if she did not comply. Because additional evidence was required to establish probable cause that defendant committed the offense of human trafficking, the alleged statement by defendant about receiving a financial benefit constituted a mere admission and not a confession of guilt.” Thus, the corpus delicti rule was not violated. “Defendant’s admission related to only one element of the crime, and the corpus delicti rule does not require independent proof of every element.” Affirmed.