Opinion

People of Michigan v. John Henry Lewis

Court
Michigan Court of Appeals
Filed
May 5, 2026
Status
Unpublished
Cited by
0 cases
Authority
More cited than 40.5%

“Where the reasons given by the trial court are inadequate or not legally recognized, the trial court abused its discretion.”

How later courts described this case

  • “Where the reasons given by the trial court are inadequate or not legally recognized, the trial court abused its discretion.”
  • review of motion for new trial

Written by the judges who cited it.

The opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to

revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED

May 05, 2026

Plaintiff-Appellee, 10:48 AM

v No. 366385

Berrien Circuit Court

JOHN HENRY LEWIS, LC No. 2022-001714-FH

Defendant-Appellant.

Before: TREBILCOCK, P.J., and BOONSTRA and LETICA, JJ.

TREBILCOCK, P.J. (dissenting).

I respectfully disagree with the majority that we can look past what I discern as the trial

court’s erroneous disregarding of MCR 6.431(B) when it denied defendant’s motion for a new

trial.

The mandatory nature of MCR 6.431(B) is apparent on its face: “The court must state its

reasons for granting or denying a new trial orally on the record or in a written ruling made a part

of the record.” (Emphasis added.) This court rule plainly dictates that a trial court’s findings of

fact and conclusions of law regarding a motion for a new trial are necessary to facilitate our

appellate review. That is especially important when dealing, as here, with mixed questions of fact

and law, see People v Armstrong, 490 Mich 281, 289; 806 NW2d 676 (2011) (review of

ineffective-assistance-of-counsel claims), and the ultimate review standard being abuse of

discretion, see People v Miller, 482 Mich 540, 544; 759 NW2d 850 (2008) (review of motion for

new trial).

All parties agree the trial court did not make any specific factual findings or legal

conclusions, and rather just summarily announced that defendant “failed to establish ineffective

assistance of trial counsel.” That non-specific conclusion prohibits us from deciding one way or

the other whether the trial court abused its discretion; simply, how can we review the trial court’s

denial of defendant’s motion for a new trial for abuse of discretion without knowing the specific

reasons the court relied upon? See People v Leonard, 224 Mich App 569, 580; 569 NW2d 663

(1997) (“Where the reasons given by the trial court are inadequate or not legally recognized, the

trial court abused its discretion.”).

-1-

Citing MCR 2.517(A)(4), my colleagues excuse the trial court’s failure to adhere to the

requirements of MCR 6.431(B). I agree that provision exempts trial courts from generally making

factual findings and legal conclusions when resolving motions. But I cannot agree that rule applies

here because the rule’s entirety makes clear there is an applicable exception: “Findings of fact and

conclusions of law are unnecessary in decisions on motions unless findings are required by a

particular rule.” MCR 2.517(A)(4) (emphasis added). The “particular rule” that requires findings

in this case is the one governing motions for a new trial, MCR 6.431.

In sum, I would not review the record de novo without the benefit of the trial court’s first

view on the facts or law. I would, therefore, remand for the trial court to articulate its reasoning

for denying defendant’s motion for a new trial.

/s/ Christopher M. Trebilcock

-2-

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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