A divided Michigan Supreme Court released its 32-page decision in People v Samuels (164050) on Friday.

I deleted the Syllabus pages and put Claude.ai (a next-generation AI assistant) to work on the majority and dissenting opinions.

First, I asked Claudi.ai to outline the decision using this complex prompt:

Draft an opinion outline of the attached court opinion which extracts the following information, follows this format, and uses these labels. If a question cannot be answered by the document, say so.

1.0 Case name(s):
1.1 Court name:
1.2 Docket (or file) number(s):
1.3 Argument (argued) date (if any):
1.4 Decision date:

2.0 Statement of facts:
2.1 Relationship or status of parties (include parties’ full names):
2.2 Legally relevant facts (facts tending to prove or disprove an issue before the court):
2.3 Procedurally significant facts (set out the (a) cause of action, (b) the requested relief, and (c) any raised defenses):
2.4 Acronym(s) defined:

3.0 Procedural history (the case disposition in the lower courts):
3.1 The lower court(s) decisions:
3.2 Any awarded damages:
3.3 Who appealed and why:

4.0 Issues
4.1 Substantive issue(s)
4.1.1 The disputed point(s) of law:
4.1.2 The key case facts related to the disputed point(s) of law (legally relevant facts):

4.2 Procedural issue(s)
4.2.1 What is the appealing party claiming that the lower court(s) did wrong:

5.0 Judgment: (The court’s final decision about the parties’ rights, and the court’s response to a party’s request for relief. The appellate court will generally either affirm, reverse, or reverse with instructions.)

6.0 Holding: (The statement of law that the court’s answer to the issue.)
6.1 Opinion author:
6.2 Any case law overruled (with citation(s)):
6.3 Any provision of law declared constitutional or unconstitutional:
6.4 Any newly announced legal standard(s):
6.5 List the (a) sentiment, (b) emotion, and (c) tone for the opinion.

7.0 Rule of law or applied legal principle: (The rule(s) of law that the court applied to determine the parties’ substantive rights. The rule(s) of law could be based on constitution, statute, case law, regulation, or court rule. The rule(s) or legal principle(s) may be expressly stated in the opinion or it may be implied.)

8.0 Reasoning:
8.1 Explain the way the court applied the rules/legal principles to the particular facts to reach its decision. This includes syllogistic application of rules and policy arguments the court used to justify its holding (why the decision was socially
desirable).
8.2 List the opinion’s headings and subheadings in text. Use sentence-case capitalization.
8.3 Note any image(s), figure(s), table(s), or charts in the majority opinion, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.
8.4 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

9.0 Non-majority opinion(s)
9.1 Name of each concurring (only) judge. Explain their reason(s) for writing separate from the majority opinion:
9.1.1 List the headings and subheadings used in each concurring (only) opinion in text. Use sentence-case capitalization.
9.1.2 List the (a) sentiment, (b) emotion, and (c) tone for each concurring (only) judge’s opinion.
9.1.3 Note any image(s), figure(s), table(s), or charts in each concurring opinion, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.
9.1.4 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

9.2 Name of each dissenting (only) judge. Explain their reason(s) for refusing to join in the majority opinion:
9.2.1 List the headings and subheadings used in each dissenting (only) opinion in text. Use sentence-case capitalization.
9.2.2 List the (a) sentiment, (b) emotion, and (c) tone for each dissenting (only) judge’s opinion.
9.2.3 Quote the sentences the judge used to express their dissent (such as “I respectfully dissent” or “I dissent”).
9.2.4 Note any image(s), figure(s), table(s), or charts in each dissenting opinion, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.
9.2.5 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

9.3 Name each judge who wrote an opinion that both concurred in part and dissented in part from the majority opinion. Explain the reason(s) for it:
9.3.1 List the headings and subheadings used in each opinion that both concurred in part and dissented in part in text. Use sentence-case capitalization.
9.3.2 List the (a) sentiment, (b) emotion, and (c) tone for each opinion that both concurred and dissented.
9.3.3 Note any image(s), figure(s), table(s), or charts in each opinion that both concurred and dissented, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.
9.3.4 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

10.0 Nonparticipating jurists
10.1 Name of each judge who did not participate in the decision and outline their reason(s) why:

11.0 Additional comments or impressions: (Is the reasoning sound and, if so, how? Is the reasoning contradictory and, if so, how? What could be the decision’s political, economic, or social effects, if any?)

Now bold the labels.

Claude.ai’s response was impressive. (A smidge incomplete, but dealt with through a simple follow-up prompt.)

Here is an outline of the court opinion based on the requested format:

1.0 Case name(s): People of the State of Michigan v. Dwight T. Samuels

1.1 Court name: Michigan Supreme Court

1.2 Docket (or file) number(s): No. 164050

1.3 Argument (argued) date (if any): Not provided in the document

1.4 Decision date: July 12, 2024

2.0 Statement of facts:

2.1 Relationship or status of parties (include parties’ full names):

• Plaintiff-Appellee: People of the State of Michigan
• Defendant-Appellant: Dwight T. Samuels

2.2 Legally relevant facts (facts tending to prove or disprove an issue before the court):

• On June 19, 2019, Dwight T. Samuels and his twin brother, Duane Samuels, were involved in a fight at a restaurant.
• The prosecutor offered a package-deal plea offer to both Dwight and Duane Samuels.
• The offer was contingent upon both defendants accepting the plea offer.
• Dwight initially objected to the package-deal plea offer but changed his mind after his twin brother indicated he wished to plead guilty.
• Both brothers then pleaded guilty in accordance with the package-deal plea offer.

2.3 Procedurally significant facts (set out the (a) cause of action, (b) the requested relief, and (c) any raised defenses):
(a) Cause of action: Dwight T. Samuels was charged as a fourth-offense habitual offender with assault with intent to commit murder, assault with intent to do great bodily harm less than murder, felon in possession of a firearm, carrying a concealed weapon, and three counts of possession of a firearm during the commission of a felony.

(b) Requested relief: At sentencing, Dwight Samuels moved to withdraw his guilty plea, arguing that it was involuntary.

(c) Raised defenses: Samuels argued that the conditional format of the package-deal plea offer was coercive and left him with no choice but to plead guilty.

2.4 Acronym(s) defined: None provided in the document.

3.0 Procedural history (the case disposition in the lower courts):

3.1 The lower court(s) decisions:

• The trial court summarily denied the motions to withdraw the pleas without first holding an evidentiary hearing.
• The Court of Appeals initially denied Samuels’ application for leave to appeal.
• After remand from the Supreme Court, the Court of Appeals affirmed the trial court’s denial of Samuels’ motion to withdraw his plea without an evidentiary hearing.

3.2 Any awarded damages: Not mentioned in the document.

3.3 Who appealed and why:
Dwight T. Samuels appealed, seeking to withdraw his guilty plea on the grounds that it was involuntary due to the nature of the package-deal plea offer.

4.0 Issues

4.1 Substantive issue(s)

4.1.1 The disputed point(s) of law:

• How should voluntariness be addressed in the context of a package-deal plea offer where the prosecutor requires that multiple defendants all agree to the plea offer for any single defendant to receive the benefit of the plea?

4.1.2 The key case facts related to the disputed point(s) of law (legally relevant facts):

• The prosecutor offered a package-deal plea offer to both Dwight and Duane Samuels.
• The offer was contingent upon both defendants accepting the plea offer.
• Dwight Samuels initially objected to the package-deal plea offer but changed his mind after his twin brother indicated he wished to plead guilty.

4.2 Procedural issue(s)

4.2.1 What is the appealing party claiming that the lower court(s) did wrong:
The appealing party (Dwight Samuels) is claiming that the lower courts erred by not holding an evidentiary hearing to determine the voluntariness of his guilty plea in the context of a package-deal plea offer.

5.0 Judgment:
The Michigan Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the trial court to conduct an evidentiary hearing on the voluntariness of Samuels’ plea.

6.0 Holding:
Where the record raises a question of fact about the voluntariness of a package-deal plea, a trial court must hold an evidentiary hearing to consider the totality of the circumstances in determining whether a defendant’s plea was involuntary.

6.1 Opinion author: Justice Bernstein

6.2 Any case law overruled (with citation(s)): None mentioned in the document.

6.3 Any provision of law declared constitutional or unconstitutional: None mentioned in the document.

6.4 Any newly announced legal standard(s):
The court adopted a totality-of-the-circumstances test, based on the factors outlined in In re Ibarra, to determine the voluntariness of a plea in the context of a package-deal plea offer.

6.5 List the (a) sentiment, (b) emotion, and (c) tone for the opinion.
(a) Sentiment: Cautious
(b) Emotion: Concern for due process
(c) Tone: Analytical and instructive

7.0 Rule of law or applied legal principle:
A defendant’s plea is involuntary if, under the totality of the circumstances, their will was overborne such that the decision to plead was not the product of free will.

8.0 Reasoning:

8.1 Explain the way the court applied the rules/legal principles to the particular facts to reach its decision. This includes syllogistic application of rules and policy arguments the court used to justify its holding (why the decision was socially desirable).

The court reasoned that:

1. Package-deal plea offers may pose a greater danger of inducing false pleas than individual plea offers due to extraneous factors.
2. The existing plea-taking process (MCR 6.302) might not be sufficient to ensure voluntariness in all cases involving package-deal pleas.
3. A totality-of-the-circumstances inquiry, based on the factors outlined in In re Ibarra, is necessary to properly assess the voluntariness of a plea in the context of a package-deal offer.
4. This approach balances the need to protect defendants’ rights with the practical considerations of the criminal justice system.
5. The record in this case raised a question of fact about the voluntariness of Samuels’ plea, warranting an evidentiary hearing.

The court justified its holding by emphasizing the importance of ensuring that guilty pleas are truly voluntary, especially in situations where external pressures (like package-deal offers) may influence a defendant’s decision.

8.2 List the opinion’s headings and subheadings in text. Use sentence-case capitalization.

I. Factual background and procedural history
II. Guilty pleas
III. Package-deal plea offers
IV. The Ibarra factors
V. Application
VI. Conclusion

8.3 Note any image(s), figure(s), table(s), or charts in the majority opinion, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.

The document does not mention any images, figures, tables, or charts in the majority opinion.

8.4 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

The document does not mention any dictionary references.

9.0 Non-majority opinion(s)

9.1 Name of each concurring (only) judge. Explain their reason(s) for writing separate from the majority opinion:

The document does not mention any concurring opinions.

9.2 Name of each dissenting (only) judge. Explain their reason(s) for refusing to join in the majority opinion:

Justice Zahra, joined by Justice Viviano, wrote a dissenting opinion.

9.2.1 List the headings and subheadings used in each dissenting (only) opinion in text. Use sentence-case capitalization.

I. Analysis
II. Conclusion

9.2.2 List the (a) sentiment, (b) emotion, and (c) tone for each dissenting (only) judge’s opinion.

(a) Sentiment: Disapproval
(b) Emotion: Frustration
(c) Tone: Critical and concerned

9.2.3 Quote the sentences the judge used to express their dissent (such as “I respectfully dissent” or “I dissent”).

“Accordingly, I dissent.”

9.2.4 Note any image(s), figure(s), table(s), or charts in each dissenting opinion, and (a) repeat any text-based caption, and (b) describe each image, figure, table, or chart as they appear.

The document does not mention any images, figures, tables, or charts in the dissenting opinion.

9.2.5 Note any dictionary references and (a) list each dictionary name, and (b) repeat any text-based term and the cited dictionary definition.

The document does not mention any dictionary references in the dissenting opinion.

9.3 Name each judge who wrote an opinion that both concurred in part and dissented in part from the majority opinion. Explain the reason(s) for it:

The document does not mention any opinions that both concurred in part and dissented in part.

10.0 Nonparticipating jurists

10.1 Name of each judge who did not participate in the decision and outline their reason(s) why:

The document does not mention any nonparticipating jurists.

11.0 Additional comments or impressions:

The majority’s decision to adopt the Ibarra factors for assessing the voluntariness of package-deal pleas represents a significant shift in Michigan law. While this approach may provide greater protection for defendants’ rights, it could also complicate the plea bargaining process and increase the workload for trial courts. The dissenting opinion raises valid concerns about the potential unintended consequences of this decision, such as making prosecutors less likely to offer plea bargains to codefendants. The long-term effects of this ruling on the criminal justice system in Michigan remain to be seen.

Claude.ai’s response to 9.2 did not explain the dissent’s reason(s) for refusing to join in the majority opinion. So I posed a follow-up:

What reasons did Justices Zahra and Viviano give for not joining in the majority opinion?

Claude.ai’s response nailed it:

According to the dissenting opinion written by Justice Zahra and joined by Justice Viviano, their main reasons for not joining the majority opinion were:

1. They believed the existing rules (MCR 6.302 and MCR 6.310) sufficiently protect a defendant’s constitutional rights by ensuring that pleas are voluntary.
2. They argued that the majority’s approach undermines MCR 6.302 and MCR 6.310 by creating a new route to withdraw a plea on a late claim of involuntariness, even when the trial court did not err in applying MCR 6.302.
3. They contended that the majority’s decision makes Michigan the first jurisdiction to require a second plea colloquy whenever a defendant who pleaded guilty in a joint plea alleges involuntariness merely because it was part of a joint plea deal.
4. They expressed concern that the majority’s approach would unnecessarily burden trial courts and prosecutors’ offices by complicating the validity of joint plea deals.
5. They argued that the majority’s decision could harm defendants by making it less likely that prosecutors will offer plea bargains to codefendants, potentially forcing defendants to go to trial and risk convictions of greater offenses and longer sentences.
6. They preferred the approach used by federal courts, which they saw as simpler and more efficient, requiring only a determination of whether there was probable cause to prosecute each defendant in a joint plea deal.
7. They believed the majority was improperly expanding the application of the Ibarra factors beyond their original context in California, where they were used during the plea-taking process rather than in considering motions to withdraw pleas.

Overall, Justices Zahra and Viviano dissented because they felt the majority’s approach was unnecessary, burdensome, and potentially harmful to the efficiency of the criminal justice system and to defendants themselves.

Next, I asked Claude.ai to boil down the opinion in a way that would probably matter to Michigan trial court judges:

What are the important points/takeaways for Michigan trial court judges based on the attached Michigan Supreme Court decision?

I think Claude.ai got it right, including noting the disagreement between the majority and dissenting opinions:

Based on the Michigan Supreme Court decision in People v. Samuels, here are some key takeaways for Michigan trial court judges:

1. When a defendant claims their plea was involuntary due to being part of a package-deal plea offer involving multiple defendants, and the record raises a question of fact about voluntariness, the trial court must hold an evidentiary hearing.
2. At this evidentiary hearing, the court must consider the totality of the circumstances to determine if the defendant’s plea was truly voluntary.
3. The court should apply the non-exhaustive factors outlined in In re Ibarra when conducting this totality of circumstances analysis, including:

• Whether the inducement for the plea was proper
• The factual basis for the guilty plea
• The nature and degree of coerciveness
• How significant the promise of leniency to others was in the defendant’s decision
• Other relevant factors like the defendant’s age, who initiated plea negotiations, etc.

4. A plea is considered involuntary if, under the totality of circumstances, the defendant’s will was overborne such that the decision to plead was not the product of free will.
5. This new requirement applies not just to pleas involving relatives, but to any package-deal plea offers involving multiple defendants.
6. Trial judges should be aware this creates an additional procedural step beyond the normal plea colloquy requirements of MCR 6.302 when package deals are involved and voluntariness is challenged.
7. However, this evidentiary hearing is only required if the record raises a factual question about voluntariness that is not directly contradicted by the defendant’s testimony at the original plea hearing.
8. The majority and dissenting opinions reveal disagreement on the court about whether this additional step is necessary, so further clarification may come in future cases.

Last, I asked Claude.ai to create a comparative table.

Create a three-column table that outlines the key argument differences between the majority and dissenting opinions.

Claude.ai made quick work of it:

Here’s a three-column table outlining the key argument differences between the majority and dissenting opinions:

Issue	Majority Opinion	Dissenting Opinion
Applicability of Ibarra factors	Should be applied to motions to withdraw pleas in package-deal cases	Should not be applied; no other jurisdiction has applied Ibarra to motions to withdraw pleas
Evidentiary hearing requirement	Required when the record raises a question of fact about voluntariness	Not necessary; current rules (MCR 6.302 and 6.310) are sufficient
Scope of application	Applies to all package-deal pleas, not just those involving relatives	Criticizes expansion beyond relatives without explanation
Voluntariness assessment	Totality-of-circumstances analysis using Ibarra factors	Simple probable cause test for prosecuting co-defendants is sufficient
Burden on courts and prosecutors	Acknowledges increased burden but deems it necessary	Argues it unnecessarily doubles work and complicates plea processes
Impact on plea bargains	Not directly addressed	Warns it may lead to fewer plea offers, harming defendants
Consistency with existing rules	Adds to existing protections	Argues it undermines MCR 6.302 and 6.310
Alignment with other jurisdictions	Cites other state courts as support	Argues federal approach is wiser and more widely accepted