People v. Klungle

Summary

The Michigan Supreme Court held that trial counsel's concession of Richard Klungle's guilt on a trespassing charge—made for the first time in closing argument and without ever consulting Klungle, who had consistently asserted his innocence—violated Klungle's Sixth Amendment right of autonomy to maintain innocence as the objective of his defense. Applying McCoy v. Louisiana, the Court held that this autonomy right applies in noncapital prosecutions, that Florida v. Nixon's contrary rule is confined to cases where counsel consulted an unresponsive client, and that the resulting structural error requires automatic reversal without a prejudice showing. The Court further held that no contemporaneous objection is required either to establish or to preserve a McCoy claim, which Klungle preserved through a timely postjudgment motion for new trial and evidentiary hearing. Because the conceded trespass charge was intertwined with the lawful-act element of the resisting-or-obstructing charges, the structural error was intrinsically harmful as to all counts, requiring reversal of the Court of Appeals, vacation of all convictions and sentences, and remand for a new trial.