The prosecution’s standing to bring charges; The trial court’s subject-matter & personal jurisdiction; Speedy trial right; People v Williams; Delay; Prosecutorial misconduct; Suppressing exculpatory evidence; Failure to correct perjured testimony

Finding no errors, the court affirmed defendant’s convictions of first-degree child abuse, armed robbery, first-degree home invasion, kidnapping, and unlawful imprisonment. He challenged personal and subject-matter jurisdiction, and asserted the prosecution lacked standing to bring the charges against him because the victim (his biological son) is not a U.S. citizen. He also contended “that the prosecution violated the 180-day rule, MCL 780.131(1), and committed misconduct” during the trial. The court held that “the prosecution has standing granted by law to prosecute criminal allegations, and defendant’s standing argument” lacked merit. The court was “similarly unpersuaded by his challenges to the [trial] court’s exercise of jurisdiction.” It found that the trial court “had personal jurisdiction over defendant because he was bound over for trial following a preliminary” exam. Further, “the trial court properly exercised subject-matter jurisdiction over the case because Michigan circuit courts have subject-matter jurisdiction over felony criminal cases, . . . and defendant was charged with multiple felonies.” The court also concluded that, on “balance, the factors set forth in Williams weigh against finding a speedy-trial violation.” Thus, defendant had “not established that the trial court erred by denying his motion to dismiss on that basis.” As to his prosecutorial misconduct claim alleging failure to correct perjured testimony, the court held that standing alone, defendant’s testimony established “only a credibility question; it does not establish that [a witness’s] testimony was false” Thus, defendant did not show “that the prosecutor erred by presenting that testimony.” In addition, absent “a showing that the original birth certificate was in some way material or exculpatory, defendant cannot establish that the prosecution improperly suppressed that evidence.”