People v. Vallance

In People v. Vallance, 216 Mich. App. 415, 419; 548 N.W.2d 718 (1996), the defendant was convicted of obstruction of justice for the intimidation of a witness in a criminal proceeding. On appeal, this Court questioned whether the People v. Thomas (1991) opinion limited the scope of offenses constituting "obstruction of justice" to the twenty-two offenses listed by Blackstone or whether the Court merely referred to Blackstone's list to illustrate the point that, at common law, "obstruction of justice" was not a single offense but rather a category of offenses. Vallance, 216 Mich. App. at 418-419. The Court ultimately concluded that obstruction of justice is a category of offenses not limited to the twenty-two offenses listed by Blackstone: We find nothing in the Thomas analysis to suggest that offenses recognized at common law as obstruction of justice are, nonetheless, not to be so considered if they are not included in the Blackstone list. . . . Accordingly, we conclude that the Supreme Court's reference in Thomas to Blackstone was merely to illustrate the point that at common law, "obstruction of justice" is not a single offense, but a category of offenses that interfere with public justice. . . . A charge of obstruction of justice was warranted if defendant's conduct would have been recognized as one of the many offenses falling within the rubric "obstruction of justice" at common law. Vallance, 216 Mich. App. at 419.