People v. Crumbley

Facts

Ds were the parents of EC who was 15 years old at the time of the murders. Jennifer worked full-time in the marketing department of a real estate company, while James worked for DoorDash, a food delivery company. By early 2021 EC began verbalizing situations he was experiencing that reflected instability in his mental health. In March, EC sent a series of text messages to Jennifer explaining his desire for Jennifer to come home, because someone was in the house with him. Neither defendant called EC that night. A week later there was a demon in the house that was throwing objects inside the house, and he had taken a picture of it. Ds did not respond. Ds were riding horses at the time the demon messages were sent. EC continued to experience hallucination-type events. On April 5, 2021, EC sent text messages to his friend telling him he was 'going to ask my parents to go to the doctor's tomorrow or Tuesday again,' 'but this time I'm going to tell them about the voices,' and 'I only told them about the people I saw.' Amongst other things, EC told his friend that he had researched his symptoms and believed he was having a mental breakdown. EC had asked his parents for medical help but James refused the request, instead giving him some pills and telling him to 'suck it up.' Jennifer did not believe he had any mental health issues but was instead using drugs. EC considered calling 911 so someone would take him to the hospital where he could get help. Some of the messages with friends involved conversations about wanting guns and making plans to buy them. EC shot an 11-second video showing him loading a magazine into a .22-caliber Kel-Tec handgun registered to James. James had left it out. EC then said, 'now it's time to shoot up the school,' and 'JKJKJKJKJK.' (JK is just kidding). EC also kept a journal. Every one of the 21 pages of written material had reference to plans to commit a school shooting. In one entry, for example, EC wrote, 'I will cause the biggest school shooting in Michigan's history,' and, 'I will kill everyone I f**king see.' On November 26, James and EC went to a gun shop. The form James signed indicated that purchasing a gun for someone else was illegal. When the background check cleared, James purchased the SIG Sauer, which was given to him in a case containing a cable lock, a trigger lock, an ATF Youth Handgun Notice Act pamphlet, and extra magazines of ammunition. EC posted two photographs and a video on his Instagram account. Both photographs were of the SIG Sauer, and the video showed EC holding the gun. In the background of the video, the gun case, ATF pamphlet, and unopened gun lock are visible. The caption on EC's Instagram post stated: 'Just got my new beauty today, [heart-eyes emoji]. SIG Sauer 9-millimeter. Ask any questions, I will answer.' The next day Jennifer took EC to a shooting range. Upon arrival, Jennifer purchased 30 minutes of range time, paper targets, and two boxes of nine-millimeter ammunition. EC took the gun apart, put it back inside the case, grabbed the used paper targets, took the leftover ammunition, and left with Jennifer. ennifer posted photographs of the paper target and the gun in its case on her own Instagram account, captioning her post with: 'Mom and son day, testing out his new X-mas present. EC posted on Instagram too about getting used to the new sites. On November 29, Jennifer performed an internet search on treatment options for clinical depression. Later that morning, EC was back at school. While in class, a teacher saw him looking at handgun ammunition on his cell phone. The teacher informed Mr. Ejack, Dean of Students, who forwarded the message to EC's school counselor, Shawn Hopkins, and another school official. Hopkins and the official met with EC that day and asked him about his cell phone activity. EC explained he was looking at ammunition because shooting guns was a hobby, and he had just gone to the shooting range with Jennifer and wanted to look up different bullets. Although EC was '[c]ompliant, calm, [and] understanding' during the meeting, and acknowledged researching ammunition was not a proper classroom activity, a school official attempted to contact Jennifer about the incident, leaving a voicemail explaining that 'guns may be a hobby and there's nothing wrong with that,' but that it was improper classroom activity. The official did not request Jennifer call back, and she did not do so. EC and Jennifer texted about the incident. On the morning of November 30, Jennifer went to work, James went to the barn to check on a sick horse, and EC went to school. In EC's backpack was the SIG Sauer handgun and his journal. EC was caught watching a shooting video on his cell phone, which the teacher reported to Ejack. Ejack forwarded the message to Hopkins at 8:30 a.m. By the time Hopkins saw the e-mail at 8:50 a.m., EC had switched to math class. At about the same time, another message was delivered to Ejack from EC's math teacher, who had photographed EC's handwriting and drawings on a math worksheet. After Ejack went to Hopkins's office to discuss the math worksheet, Hopkins went to EC's classroom, grabbed the worksheet (which EC had already attempted to modify) off the desk, and walked EC to the office. The modifications EC made to the original worksheet were significant. EC scribbled out the gun (which closely resembled the SIG Sauer), the person bleeding from bullet holes, and the phrases 'Help me,' 'My life is useless,' 'the world is dead,' and 'Blood everywhere.' Added to the worksheet were statements that 'I love my life so much,' 'Harmless act,' 'Were all friends here,' 'OHS Rocks!' and 'Video game this is.' The modified worksheet provided a more complete picture of how EC tried to cover up what he initially wrote and drew. EC said the drawing was about a video game. When asked about the statement that 'my life is useless,' EC's demeanor changed. EC became sad and started discussing his various troubles in life, specifically mentioning his friend moving away, difficulty dealing with the restrictions put in place to address the COVID-19 pandemic, and his dog and grandparent dying. EC also mentioned that he argued with his parents the night before regarding his grades. Hopkins performed a 'risk assessment' related to EC. Jennifer was asked to come to school to discuss EC's situation. Hopkins forwarded Jennifer photographs of the math worksheet (before and after modification) while they were speaking. Jennifer informed Hopkins that she would contact James to see who would come to school. Hopkins informed defendants about the video EC had been watching during his first hour class (he had already sent Jennifer both versions of the math worksheet), told defendants he was concerned about EC's mental health, provided them with mental health resources, and recommended they immediately take EC to a doctor or therapist that day. Ds responded that they needed to return to work. Hopkins insisted that EC get medical attention within 48 hours. Ds leaf Oxford High School at 10:54 a.m. and driving out of the parking lot at 10:56 a.m. Ds returned to work. At 12:21 p.m., Jennifer sent a text message to EC asking if he was okay, and he responded he was and had just finished lunch. Jennifer then wrote, '[y]ou know you can talk to us and we won't judge,' to which EC responded at 12:42 p.m., 'IK thank you. I'm sorry for that. I love you.' Fewer than 10 minutes after sending that message, EC went into a bathroom with his backpack, came out with the SIG Sauer, and committed the murders while also injuring six other students and one teacher. By 12:58 p.m., the shooting was over. Oxford High School sent out alerts to parents about an active shooter within the school. Jennifer received the information while at work and started screaming. Police executed a search warrant and found the gun case for the SIG Sauer open on the bed next to an empty box of nine-millimeter ammunition and a locked gun safe in a dresser drawer of Ds' bedroom. The safe had a three-digit combination lock, which was set as '000,' and contained James's other two guns. All of the gun locks found in the house were still in their original packaging. Detective Stoyek did not find any broken locks or a lock with which someone had tampered. Felony complaints were issued alleging Ds' grossly negligent conduct caused the deaths of the four victims by failure to properly store the gun and ammunition and to properly supervise and care for EC. The district court decided to bind over Ds as charged. The court found that the deaths of the four victims could have been avoided if Ds had exercised ordinary care and diligence in the care of their son. The court found that EC presented a danger to the community; that the danger was apparent to an ordinary mind; that Ds neglected to diligently address and/or divert that danger; and, that the danger resulted in the four deaths of the young children at Oxford High School. EC was certainly a troubled young man and Ds had knowledge of that situation, but they purchased a gun which he believed was his and that he was free to use. Ds filed a motion to quash the bindover, contending that the district court abused its discretion by finding probable cause existed to believe Ds committed involuntary manslaughter. Ds claimed that the prosecution could not prove causation. The Court concluded that the criminal misconduct of Ds' son was an intervening cause but that a reasonable juror could conclude that his actions were reasonably foreseeable. Therefore, the causal link between Ds' actions and their liability for the deaths of the victims, as alleged by the People, is not severed by the actions of their son. It denied the motion to quash. Ds appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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