People v. Goodwin

In People v. Goodwin, 69 Mich. App. 471; 245 N.W.2d 96 (1976), the Court held that the defendant had the right to a jury trial because the misdemeanor offense charged, speeding in excess of the posted speed limit, was a "crime" and "our Michigan Constitution provides the right to a trial by jury in all criminal prosecutions." Id. at 473. The Goodwin panel acknowledged that there is "a host of United States Supreme Court cases for the proposition that a jury trial is not mandatory where a 'petty' offense is involved" and suggested that "the cause of justice might be better served were the right to jury trial precluded in such petty offenses." Id. at 474. Nevertheless, the Court explicitly rejected any attempt to align the interpretation of Const 1963, art 1, 20 with the Sixth Amendment, noting that "it is also axiomatic that the state can grant its citizens rights which are greater than those in the United States Constitution" and that Michigan case law does support a broader right under the state constitution. Goodwin, supra at 473.