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People v. Stamper
Citations: 742 N.W.2d 607; 480 Mich. 1Docket: Docket 132887
Court: Michigan Supreme Court; December 27, 2007; Michigan; State Supreme Court
Original Court Document: View Document
In the case of *People of the State of Michigan v. Michael William Stamper*, the Michigan Supreme Court addressed whether a four-year-old child could possess the awareness of impending death necessary for his statements to be considered admissible under the dying declaration exception to the hearsay rule, as outlined in MRE 804(b)(2). The court affirmed the defendant's convictions, ruling that the child, Jake Logan, could indeed have such awareness. The facts established that after a bath given by the defendant, Jake exhibited signs of distress, stating to his mother, "Mom, I can’t, I’m dead," and later confirming to others that he had been harmed by "Mike," identified as the defendant. Medical examination revealed multiple bruises and injuries consistent with severe abuse, leading to Jake's death shortly thereafter. The court noted that hearsay, defined as an unsworn out-of-court statement used to prove the truth of the matter asserted, is typically inadmissible unless it fits within established exceptions. The dying declaration exception allows for statements made under the belief of imminent death if the declarant is unavailable as a witness. The trial court had initially admitted Jake's statements under this exception, which was upheld by the Court of Appeals. The ruling emphasized that a trial court must conduct a preliminary investigation into the circumstances surrounding a dying declaration to ensure it reflects the declarant's belief in impending death. The court's decision underscores the legal standard for determining the admissibility of such statements, affirming the importance of evaluating the declarant's state of mind at the time the statement was made. Statements regarding the cause or circumstances of a declarant's impending death can be admitted as substantive evidence under MRE 804(b)(2) if it is clear that the declarant believed death was imminent. In this case, Jake, who was unavailable as a witness, expressed to his mother, "Mom, I can’t, I’m dead," indicating his belief in his imminent death, supported by his injuries. His statements to nurses about receiving injuries from "Mike," whom he identified as "Mom’s wife," further detailed the circumstances surrounding his impending death. The court rejected the defendant’s assertion that a four-year-old cannot be aware of impending death, emphasizing that awareness must be assessed on a case-by-case basis. Since the facts demonstrated that Jake believed he was about to die, his statements qualify as dying declarations regardless of his age. The Court of Appeals’ decision to uphold the trial court's admission of these statements was affirmed, and the remainder of the defendant’s application for review was denied.