The Michigan Supreme Court issued a decision Tuesday in *People v. Robinson*, a case that challenges the validity of murder convictions obtained through Michigan's one-person grand jury process.
Todd D. Robinson was convicted in 2013 of first-degree premeditated murder and possession of a firearm during the commission of a felony following an indictment issued by a judge acting as a one-person grand jury under MCL 767.3 and MCL 767.4. The conviction occurred in Jackson Circuit Court after Robinson unsuccessfully moved to either hold a preliminary examination or quash the information before trial.
The case gained renewed significance following the Michigan Supreme Court's 2022 decision in *People v. Peeler*, which held that defendants charged under Michigan's one-person grand jury statutes are entitled to preliminary examinations. The *Peeler* decision also established that these statutes do not authorize judges serving as one-person grand juries to issue criminal indictments.
Robinson's initial direct appeal of his convictions failed, as did his first motion for relief from judgment. However, after the *Peeler* decision was issued, Robinson filed a second motion for relief from judgment in Jackson Circuit Court, arguing that his conviction was invalid under the new precedent.
The one-person grand jury procedure, codified in MCL 767.3 and MCL 767.4, has been a subject of legal debate in Michigan. Under this process, a single judge can review evidence and determine whether to issue charges, rather than requiring a traditional grand jury of citizens. Critics have argued this process lacks the procedural safeguards typically afforded to defendants, including the right to a preliminary examination.
The preliminary examination serves as a crucial protection in criminal proceedings, allowing defendants to challenge the sufficiency of evidence before trial. During such hearings, the prosecution must present evidence to establish probable cause that a crime was committed and that the defendant committed it. Defense attorneys can cross-examine witnesses and present arguments challenging the charges.
The *Peeler* precedent fundamentally altered the legal landscape for cases involving one-person grand jury indictments. That decision recognized that defendants retain their constitutional and statutory rights to preliminary examinations even when charges are brought through the one-person grand jury process.
Robinson's case represents one of potentially many convictions that could be affected by the *Peeler* ruling. Defendants who were convicted following one-person grand jury indictments without preliminary examinations may now have grounds to challenge their convictions through post-conviction relief motions.
The Michigan Supreme Court heard oral arguments in Robinson's case on October 9, 2025, after granting leave to appeal. The court's February 4, 2026 decision addresses whether Robinson's conviction should stand given the procedural irregularities identified in *Peeler*.
The case highlights broader questions about criminal procedure and defendants' rights in Michigan. The tension between efficient case processing and constitutional protections remains a central issue in criminal justice reform discussions.
Legal experts have noted that the one-person grand jury system was originally designed to streamline certain types of cases, particularly those involving complex evidence or sensitive matters. However, the *Peeler* decision and subsequent cases like *Robinson* suggest that efficiency cannot come at the expense of fundamental due process rights.
The Jackson Circuit Court, where Robinson was originally tried, will likely need to address the implications of the Supreme Court's ruling. Depending on the decision's specifics, Robinson may be entitled to a new preliminary examination or other relief.
The case also raises questions about retroactive application of new legal standards. When appellate courts establish new procedural requirements, determining which previous convictions are affected can be complex. Courts must balance the finality of judgments against the need to correct constitutional violations.
For Michigan's criminal justice system, the *Robinson* decision will provide guidance on how to handle similar cases where defendants were convicted following one-person grand jury proceedings without preliminary examinations. The ruling may establish procedures for reviewing such convictions and determining appropriate remedies.
The decision comes as Michigan continues to examine its criminal procedure statutes and their alignment with constitutional requirements. The Supreme Court's ruling will likely influence how prosecutors and defense attorneys approach cases involving the state's one-person grand jury provisions going forward.