The Michigan Court of Appeals has ruled that delays caused by COVID-19 restrictions that closed courtrooms did not deprive a murder defendant of a speedy trial.
Quatrail Terell Smith was charged in September of 2019 and was held in the Genesee County Jail for more than 30 months before his trial in April of 2022. That was while courtrooms were closed by emergency health orders to help stop the spread of the coronavirus.
Once Smith went to trial, he was convicted of a fatal triple shooting in Flint and sentenced to life without parole. His appeal, among other things, cited his lengthy pretrial incarceration as a violation of his rights under the U.S. and Michigan constitutions.
A three-judge appeals panel unanimously upheld the convictions and held the delay was rare but necessary.
“There is a difference between an unexpected delay and an inexcusable delay,” wrote Judge Kristina Robinson Garrett, and “pandemic-related delays in criminal proceedings across Michigan were neither unexplained nor inexcusable.”
Genesee County Prosecutor David Leyton said that was the right call and courts did the best they could during difficult circumstances.
“I don’t think anybody’s rights were violated,” he told Michigan Public Radio. “I think everybody still had a fair trial and I think that justice was administered correctly.”
Leyton said a trial during the pandemic would have put too many people at risk.
“It would have jeopardized the health of so many people who come in contact with the court system,” he said. “You know, prosecutors, defense lawyers, judges, court personnel and jurors, so the court determined that, in the end, the COVID-19 delay is what caused this and that should not impact the speedy trial issue.”
But Jessica Zimbelman, a managing attorney with the State Appellate Defender Office, said the case raised troubling issues with how courts and the criminal justice system handled COVID-related challenges.
“Courts were operating,” she said, “so there has to be a remedy even for people whose delay was a majority due to the pandemic because the government has deprived people of their liberty.”
The State Appellate Defender Office was not a party to the case because the defendant had a court-appointed attorney. But Zimbelman said she hopes the case will go to the Michigan Supreme Court to resolve questions about the rights of defendants whose cases were dragged out during COVID, and similar situations that might occur in the future.
Smith’s attorney did not reply to a request for comment or share any plans for an appeal to the Michigan Supreme Court.
