e-Journal Summary

e-Journal Number : 84616
Opinion Date : 10/28/2025
e-Journal Date : 11/12/2025
Court : Michigan Court of Appeals
Case Name : People v. Hubbard
Practice Area(s) : Criminal Law
Judge(s) : Per Curiam – Redford, Cameron, and Patel
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Issues:

Referring to jurors by numbers; “Anonymous jury”; People v Williams; People v Hanks; Batson v Kentucky challenge; People v Knight; Motion to suppress defendant’s police statements; Voluntariness; People v Cipriano; Sufficiency of the evidence for first-degree felony murder & premeditated murder convictions; MCL 750.316(1)(b); Premeditation; People v Oros; Double jeopardy; Two first-degree murder convictions for the death of one person; People v Coomer

Summary

The court held that (1) referring to the jurors by number did not violate defendant’s due process rights, (2) the trial court did not err in rejecting his Batson challenge, (3) his police statements were properly admitted, and (4) there was sufficient evidence to convict him of first-degree felony and premeditated murder. But his convictions and sentences for two first-degree murder counts for the death of one person violated double jeopardy. As to his first claim, nothing in the record suggested the jurors’ “biographical information was withheld from the parties. Both parties conducted extensive voir dire, and there is nothing that suggests any of the jurors believed that the use of numbers rather than their names was anything other than a common, convenient method for” managing the jury-selection process. The trial court also twice instructed the jurors “that defendant was presumed to be innocent until proven guilty.” As to his Batson challenge, the court held that he “failed to establish a prima facie showing of discrimination[.]” He next asserted that his police “statements were not voluntary because he was sleep-deprived and had been denied his psychotropic medication” in jail. But “the parties stipulated to the admission of a competency-to-stand-trial report, which noted the lack of documentation to support defendant’s claimed mental-health conditions as well as the lack of any mental-status impairment that would affect the voluntariness of his statements. Regardless of whether [he] was sleep-deprived, those that observed him found him to be coherent and capable of maintaining conversation.” The court also concluded his own admission provided “sufficient evidence that he killed the victim during the commission of the larceny.” And he stated that they “were in an argument that led to a physical struggle” during which he “stabbed the victim 75 times. The nature of the stabbing and the number of stab wounds support the reasonable inference that defendant had time to reflect before killing the victim.” But the convictions of two counts for one death violated “the constitutional protection against double jeopardy.” Thus, the court remanded “for the ministerial task of modifying the judgment of conviction and sentence to specify that he has one conviction and one sentence for first-degree murder supported by two theories: premeditated murder and felony murder.” It affirmed in all other respects.

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