# People of Michigan v. John Henry Lewis

> Michigan Court of Appeals · May 5, 2026

URL: https://www.frixlaw.com/law-library/cases/11321148

## Case

- **Court:** Michigan Court of Appeals
- **Decided:** May 5, 2026
- **Precedential status:** Unpublished
- **Opinion:** Dissent
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED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-

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11321148. Public record. Not legal advice.