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People v. Blume, 443 Mich. 476, 505 N.W.2d 843

Facts

Michael Blume, a Florida resident, was charged with conspiracy to deliver and possession with intent to deliver over 650 grams of cocaine after selling cocaine to Randall Hoyt, a Michigan resident, in Florida. Hoyt was arrested in Michigan after returning with the cocaine, and he informed police that he purchased it from Blume. The trial court dismissed the charges, concluding that any conspiracy occurred in Florida and that Blume did not aid or encourage any actions in Michigan. The circuit court reversed this decision, leading to the Supreme Court's review.

Defendant, Michael Blume, is a Florida resident who is charged in Michigan with conspiracy to deliver or possession with intent to deliver more than 650 grams of cocaine and with aiding and abetting the manufacture or possession with intent to manufacture or deliver 650 grams of cocaine. The complaint alleges that in June, 1988, defendant sold cocaine to Randall Hoyt, a Michigan resident. The entire transaction took place in Florida. After purchasing cocaine from defendant, Hoyt returned to Michigan. The Michigan State Police subsequently arrested Hoyt upon discovering a kilo of cocaine during a search of Hoyt's apartment. Hoyt informed the police that he purchased the cocaine from defendant while in Florida.

Issue

Whether Michigan may exercise extraterritorial jurisdiction over acts committed outside the state by a Florida resident that are intended to and do have a detrimental effect within Michigan.

We must decide today whether Michigan may punish acts allegedly committed in Florida by a Florida resident.

Rule

A state may exercise extraterritorial jurisdiction over acts committed outside its borders if those acts are intended to and do have a detrimental effect within the state.

We hold that Michigan may exercise extraterritorial jurisdiction over acts committed outside Michigan when the acts are intended to and do have a detrimental effect within the state.

Analysis

The court analyzed whether the prosecution provided sufficient evidence that Blume intended to produce a detrimental effect in Michigan. It concluded that mere knowledge of Hoyt's Michigan residency and the subsequent possession of cocaine in Michigan were insufficient to establish that Blume intended for the cocaine to be distributed in Michigan. The court emphasized that the prosecution failed to demonstrate that Blume had any agreement or intent regarding the distribution of the cocaine in Michigan.

The prosecutor claims that defendant was involved in a conspiracy and aided and abetted the commission of a crime in Michigan because he knew that the person to whom he sold cocaine was from Michigan. We disagree. The 'knowledge' to which the prosecutor refers only is part of the evidence necessary to support a conviction for conspiracy or aiding and abetting. But knowledge alone is not enough to exercise extraterritorial jurisdiction. The prosecutor must present evidence that defendant intended to commit an act with the intent to have a detrimental effect within this state. That intent does not exist in this case.

Conclusion

The Supreme Court reversed the Court of Appeals decision and reinstated the district court's dismissal of the charges against Blume, concluding that there was insufficient evidence to support the exercise of extraterritorial jurisdiction.

Accordingly, we reverse the Court of Appeals decision, and reinstate the district court's dismissal of the charges.

Who won?

Defendant Michael Blume prevailed in the case because the Supreme Court found that the prosecution did not provide adequate evidence of his intent to have a detrimental effect in Michigan.

Defendant must have intended to aid and abet a crime in Michigan. Mere knowledge is not enough to exercise jurisdiction.

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