flight instruction (Michigan) · Go Syfert
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flight instruction in Michigan

19 Michigan opinions name it 1 courts 2009–2025 5 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
People v. Colemangreen
michctapp · 1995 · cited in 4 Michigan opinions naming this issue, 2009–2018
2 sentences

2018See People v Coleman, 210 Mich App 1, 4 ; 532 NW2d 885 (1995).

2018See People v Coleman, 210 Mich App 1, 4 ; 532 NW2d 885 (1995).

44
People v. Gillisgreen
mich · 2006 · cited in 3 Michigan opinions naming this issue, 2015–2017
2 sentences

2017We disagree. “[A] trial court’s determination whether a jury instruction is applicable to the facts of the case is reviewed for an abuse of discretion.” People v Gillis, 474 Mich 105, 113 ; 712 NW2d 419 (2006) (quotation marks and citation omitted).

2017We disagree. “[A] trial court’s determination whether a jury instruction is applicable to the facts of the case is reviewed for an abuse of discretion.” People v Gillis, 474 Mich 105, 113 ; 712 NW2d 419 (2006) (quotation marks and citation omitted).

13
People v. Kowalskigreen
mich · 2011 · cited in 2 Michigan opinions naming this issue, 2015–2023
2 sentences

2023See People v Kowalski, 489 Mich 488, 504 ; 803 NW2d 200 (2011) (“[B]y expressly . . . approving the jury instructions on the record, defendant waived any objection to the erroneous instructions, and there is no error to review.”).

2023See People v Kowalski, 489 Mich 488, 504 ; 803 NW2d 200 (2011) (“[B]y expressly . . . approving the jury instructions on the record, defendant waived any objection to the erroneous instructions, and there is no error to review.”).

12
State v. Aekinsgreen
ohioctapp · 2023 · cited in 1 Michigan opinions naming this issue, 2025–2025
2 sentences

2025See, e.g., State v Cooper, 353 Conn 510, 561 ; 343 A3d 465 (2025); State v Aekins, 2023-Ohio-322 ; 207 NE3d 934, 968-970 (Ohio App, 2023); United States v Mireles, 116 F4th 713, 726-727 (CA 7, 2024).

2025See, e.g., State v Cooper, 353 Conn 510, 561 ; 343 A3d 465 (2025); State v Aekins, 2023-Ohio-322 ; 207 NE3d 934, 968-970 (Ohio App, 2023); United States v Mireles, 116 F4th 713, 726-727 (CA 7, 2024).

11
State v. Coopergreen
conn · 2025 · cited in 1 Michigan opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v Cooper, 353 Conn 510, 561 ; 343 A3d 465 (2025); State v Aekins, 2023-Ohio-322 ; 207 NE3d 934, 968-970 (Ohio App, 2023); United States v Mireles, 116 F4th 713, 726-727 (CA 7, 2024).

11
United States v. Jose Mireles, Jr.green
ca7 · 2024 · cited in 1 Michigan opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v Cooper, 353 Conn 510, 561 ; 343 A3d 465 (2025); State v Aekins, 2023-Ohio-322 ; 207 NE3d 934, 968-970 (Ohio App, 2023); United States v Mireles, 116 F4th 713, 726-727 (CA 7, 2024).

11
People v. Carinesgreen
mich · 1999 · cited in 1 Michigan opinions naming this issue, 2021–2021
2 sentences

2021See People v Carines, 460 Mich 750, 764 ; 597 NW2d 130 (1999).

2021See People v Carines, 460 Mich 750, 764 ; 597 NW2d 130 (1999).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
People v. Hall green
michctapp · 1989
2 sentences

2025Defendant is correct that mere departure from the scene of the crime is insufficient to support a flight instruction, People v Hall, 174 Mich App 686, 691 ; 436 NW2d 446 (1989), and Trooper Franklin Carpenter testified that there was no “extreme delay” with defendant’s arrest, as defendant exited the mobile home five or six minutes after law enforcement made announcements and banged on the residence.

2025Defendant is correct that mere departure from the scene of the crime is insufficient to support a flight instruction, People v Hall, 174 Mich App 686, 691 ; 436 NW2d 446 (1989), and Trooper Franklin Carpenter testified that there was no “extreme delay” with defendant’s arrest, as defendant exited the mobile home five or six minutes after law enforcement made announcements and banged on the residence.

62016–2025
People v. Smelley green
mich · 2010
2 sentences

2015While the flight instruction recognizes that there may be reasons for flight that are consistent with innocence, People v Smelley, 485 Mich 1023 ; 776 NW2d 310 (2010), defendant does not suggest, and the evidence did not show, any plausible innocent reason for the alleged conduct in 1 We note that, with respect to Charles’s murder, defendant was eventually convicted in the Washtenaw Circuit Court of first-degree murder, conspiracy to commit first-degree murder, witness intimidation, and felony-firearm.

2015While the flight instruction recognizes that there may be reasons for flight that are consistent with innocence, People v Smelley, 485 Mich 1023 ; 776 NW2d 310 (2010), defendant does not suggest, and the evidence did not show, any plausible innocent reason for the alleged conduct in 1 We note that, with respect to Charles’s murder, defendant was eventually convicted in the Washtenaw Circuit Court of first-degree murder, conspiracy to commit first-degree murder, witness intimidation, and felony-firearm.

32015–2017
People v. Unger green
michctapp · 2008
2 sentences

2017If that was required, flight evidence would rarely be admissible because it is obviously difficult to prove somebody’s motives.” People v Smelley, 485 Mich 1023, 1023 ; 776 NW2d 310 (2010).2 The jury must determine “whether evidence of flight occurred under such circumstances as to indicate guilt.” Unger, 278 Mich App at 226 .

2017If that was required, flight evidence would rarely be admissible because it is obviously difficult to prove somebody’s motives.” People v Smelley, 485 Mich 1023, 1023 ; 776 NW2d 310 (2010).2 The jury must determine “whether evidence of flight occurred under such circumstances as to indicate guilt.” Unger, 278 Mich App at 226 .

22017–2017
People of Michigan v. Dawn Marie Dixon-Bey green
michctapp · 2017
2 sentences

2025People v Dixon-Bey, 321 Mich App 490, 496 ; 909 NW2d 458 (2017). “[W]hether a rule or statute precludes admission of evidence is a preliminary question of law that this Court reviews de novo.” Propp, 508 Mich at 283. 5 Defendant additionally asserts, in a footnote, that “[s]o suspect is the flight instruction that twenty-two states . . . forbid, disapprove, or severely limit the flight instruction.” Not only is the law from other jurisdictions not binding on this Court, People v DeBono, 346 Mich App 64 , 70 n 2; 11 NW3d 546 (2023), but defendant ignores that the majority of states and jurisdic

2025People v Dixon-Bey, 321 Mich App 490, 496 ; 909 NW2d 458 (2017). “[W]hether a rule or statute precludes admission of evidence is a preliminary question of law that this Court reviews de novo.” Propp, 508 Mich at 283. 5 Defendant additionally asserts, in a footnote, that “[s]o suspect is the flight instruction that twenty-two states . . . forbid, disapprove, or severely limit the flight instruction.” Not only is the law from other jurisdictions not binding on this Court, People v DeBono, 346 Mich App 64 , 70 n 2; 11 NW3d 546 (2023), but defendant ignores that the majority of states and jurisdic

12025–2025
People v. Carter green
mich · 2000
2 sentences

2023People v Carter, 462 Mich 206, 215 ; 612 NW2d 144 (2000). 7 Before the instructions were given to the jury, the prosecutor asserted that defense counsel was not contesting that the flight instruction was warranted based on the evidence.

2023People v Carter, 462 Mich 206, 215 ; 612 NW2d 144 (2000). 7 Before the instructions were given to the jury, the prosecutor asserted that defense counsel was not contesting that the flight instruction was warranted based on the evidence.

12023–2023
Prince v. MacDonald green
michctapp · 1999
1 sentence

2020Id.

12020–2020
People v. Dunigan green
michctapp · 2013
2 sentences

2016Therefore, defense counsel’s decision not to request the flight instruction should be presumed to be a reasonable strategy, Vaughn, 491 Mich at 669 , a decision the Court should “not second-guess . . . with the benefit of hindsight,” People v Dunigan, 299 Mich App 579, 589-590 ; 831 NW2d 243 (2013).

2016Therefore, defense counsel’s decision not to request the flight instruction should be presumed to be a reasonable strategy, Vaughn, 491 Mich at 669 , a decision the Court should “not second-guess . . . with the benefit of hindsight,” People v Dunigan, 299 Mich App 579, 589-590 ; 831 NW2d 243 (2013).

12016–2016
United States v. Alaa Al-Sadawi green
ca2 · 2005
1 sentence

2016Al-Sadawi, 432 F3d at 424 .

12016–2016
People v. Vaughn green
mich · 2012
1 sentence

2016Therefore, defense counsel’s decision not to request the flight instruction should be presumed to be a reasonable strategy, Vaughn, 491 Mich at 669 , a decision the Court should “not second-guess . . . with the benefit of hindsight,” People v Dunigan, 299 Mich App 579, 589-590 ; 831 NW2d 243 (2013).

12016–2016
People v. Taylor green
michctapp · 1992
2 sentences

2015People v Taylor, 195 Mich App 57, 63-64 ; 489 NW2d 99 (1992).

2015People v Taylor, 195 Mich App 57, 63-64 ; 489 NW2d 99 (1992).

12015–2015

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 750.227b (9) MI § Mich. Comp. Laws § 750.224f (8) MI § Mich. Comp. Laws § 750.529 (6) MI § Mich. Comp. Laws § 769.10 (6) MI § Mich. Comp. Laws § 750.316 (5) MI § Mich. Comp. Laws § 750.83 (5) MI § Mich. Comp. Laws § 769.12 (5) MI § Mich. Comp. Laws § 750.82 (4) MI § Mich. Comp. Laws § 750.84 (4) MI § Mich. Comp. Laws § 777.33 (4) MI § Mich. Comp. Laws § 777.44 (4) MI § Mich. Comp. Laws § 777.31 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 196 (1951–2026) MS 82 (1984–2026) OH 74 (2003–2026) TN 51 (1985–2026) AZ 51 (1968–2024) FL 46 (1983–2014) NC 33 (1986–2026) OK 31 (1975–2026) PA 24 (1946–2023) NV 23 (1970–2025) MD 20 (2006–2026) MI 19 (2009–2025) IN 18 (1979–2014) CO 12 (1976–2026) IA 12 (1967–2016) UT 11 (1983–2021) RI 9 (1984–2009) NJ 9 (1992–2025) VA 8 (1993–2026) DC 8 (1980–2017) OR 7 (1977–1978) MT 6 (1999–2021) SD 6 (1975–2009) CT 6 (1989–2018) MO 5 (1925–1975) DE 5 (1983–2025) IL 5 (1966–1979) AL 4 (1998–2023) GA 4 (1991–2020) LA 4 (1998–2013) WY 3 (2000–2016) WA 2 (1974–2024) KS 2 (1979–2004) VT 2 (2020–2023) ID 2 (2014–2022) NY 2 (1987–1995) TX 2 (1986–1995) AK 2 (1967–1996) ME 2 (2018–2018) MA 2 (2010–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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