People v. Woods

In People v. Woods, 172 Mich App 476, 478-479; 432 NW2d 736 (1988), the Court explained the contours of a defendant's right to be present at his felony trial: A criminal defendant has a statutory right to be present at his trial. MCL 768.3; MSA 28.1026. An accused's right to be present at trial is also impliedly guaranteed by the federal and state constitutions and grounded in common law. A defendant may waive his right to be present by failing to appear for trial. A valid waiver of a defendant's presence at trial consists of a specific knowledge of the constitutional right and an intentional decision to abandon the protection of the constitutional right. There can be no waiver if either of these elements is missing. However, a defendant's absence from trial, whether resulting from a voluntary waiver or not, requires reversal of his or her conviction only when the defendant demonstrates that there is a "reasonable possibility of prejudice" arising from his or her absence from trial. Id. at 480.