People of Michigan v. Donte Jamelle Smith
Court
Michigan Court of Appeals
Decided
June 11, 2025
Jurisdiction
SA
Importance
45%
Practice Areas
Case Summary
If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports. STATE OF MICHIGAN COURT OF APPEALS PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 11, 2025 Plaintiff-Appellee, 2:50 PM v No. 370182 Van Buren Circuit Court DONTE JAMELLE SMITH, LC No. 2023-024625-FH Defendant-Appellant. Before: YATES, P.J., and YOUNG and WALLACE, JJ. YOUNG, J. (concurring). I write separately to discuss the evidence supporting fourth-degree fleeing and eluding. Let’s revisit the record underlying this conviction—trial testimony from Michigan State Police Trooper Alex Sussdorf. Sussdorf testified that he was the trooper who conducted the traffic stop of Smith. Sussdorf testified, “I activated my siren, multiple different tones, airhorn and eventually after an extended period of time, got on my . . . loudspeaker, and gave multiple commands to stop the vehicle.” During that time, Smith had ventured over to the shoulder of I-94 “more than a couple times” but ultimately continued down the highway to an exit ramp. At oral argument, Smith’s appellate counsel said that Smith took the first possible exit he could off of I-94. As he was exiting the freeway, Smith threw a gun out of the car window. According to Sussdorf, “[t]he stop eventually occurred off the freeway, off M-51 in the Marathon gas station right there at the corner of M-51 and I-94.” In the light most favorable to the prosecutor, Smith, who was from out-of-state and had his minor children with him in the vehicle, drove about four minutes1 without accelerating to a gas 1 A patrol car dash cam was admitted as an exhibit at trial and was not submitted to this Court to review. According to the transcript, the playing of the footage at trial of the initial traffic violation to the exit ramp took four minutes. -1- station (which is objectively safer, better-lit, and has the potential to record the encounter), and in the interim, tossed a gun. There is no question that Smith, albeit momentarily, “willfully fail[ed] to obey” the lawful direction to stop over the matter of minutes it took him to get to “the first available gas station.”2 But he did not fail to obey the police order “by increasing the speed of the motor vehicle” or “extinguishing the lights of the motor vehicle.” The question is whether Smith momentarily failed to obey by “otherwise attempting to flee or elude the officer.” On the present record before this Court, I agree with the majority that Smith tossing a gun from his car while driving a distance of two miles is enough to support that he was trying to avoid being caught and thus, eluding, the police.3 As a result, I concur. /s/ Adrienne N. Young 2 This is a quote from appellant’s brief. I cannot confirm the accuracy of this statement based on the record as I am without the dash cam video or any other record support for this claim. There is no testimony on the record refuting this. 3 At oral argument, appellate defense counsel posited that the crime of fleeing and eluding pertains only to the adherence or nonadherence to the lawful traffic stop order and not eluding a separate criminal offense (e.g. tossing a gun to avoid a gun possession charge while in the process of pulling over is destruction of evidence or something similar, not fleeing and eluding.). This argument is interesting but not before this Court at this time. It does present an issue where an opinion from the Michigan Supreme Court would be welcome to the bench and bar. -2-
Case Details
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Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
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Case Overview
Case Name: People of Michigan v. Donte Jamelle Smith
Court: Michigan Court of Appeals
Date: June 11, 2025
Citation: Unknown
Jurisdiction: SA
This case involves the appeal of Donte Jamelle Smith against the decision of the Van Buren Circuit Court regarding charges of fourth-degree fleeing and eluding law enforcement. The court's ruling centers on the interpretation of Smith's actions during a traffic stop conducted by Michigan State Police.
Key Legal Issues
- Fleeing and Eluding: Whether Smith's actions constituted fleeing and eluding law enforcement under Michigan law.
- Evidence Evaluation: The sufficiency of evidence presented to support the conviction.
Court's Decision
The Michigan Court of Appeals upheld the conviction of Donte Jamelle Smith for fourth-degree fleeing and eluding. The court found that Smith's actions during the traffic stop met the criteria for eluding law enforcement, despite arguments to the contrary by the defense.
Legal Reasoning
Judge Young, in a concurring opinion, emphasized the importance of the evidence presented at trial, particularly the testimony of Trooper Alex Sussdorf. Key points from the court's reasoning include:
- Traffic Stop Dynamics: Smith failed to stop immediately when signaled by the police, which is a critical factor in establishing the offense of fleeing and eluding.
- Duration and Behavior: Smith's decision to drive for approximately four minutes before stopping, during which he tossed a gun from the vehicle, indicated an attempt to evade law enforcement.
- Legal Interpretation: The court interpreted Smith's actions as willfully failing to obey police commands, which constitutes eluding under Michigan law.
Key Holdings
- The court affirmed that Smith's actions of driving away from the police and discarding a firearm constituted fleeing and eluding.
- The evidence presented was sufficient to support the conviction, highlighting the importance of a police officer's testimony in establishing the facts of the case.
Precedents and Citations
- The court did not cite specific precedents in this unpublished opinion, but the discussion raises questions about the interpretation of fleeing and eluding laws in Michigan.
- The case may prompt further clarification from the Michigan Supreme Court regarding the nuances of fleeing and eluding in relation to other criminal offenses.
Practical Implications
- Law Enforcement Training: This case underscores the need for law enforcement officers to document and present clear evidence during traffic stop incidents.
- Legal Defense Strategies: Defense attorneys may need to refine their arguments regarding the definition of fleeing and eluding, especially in cases involving additional criminal conduct, such as possession of a firearm.
- Public Awareness: The ruling serves as a reminder to the public about the legal consequences of failing to comply with police orders during traffic stops.
In conclusion, the Michigan Court of Appeals' ruling in People of Michigan v. Donte Jamelle Smith highlights significant aspects of fleeing and eluding laws, the importance of evidence in legal proceedings, and the potential for further legal interpretation in future cases.
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Case Details
Legal case information
Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools