DueProcess HabeasCorpus
Whether the state trial court lacked subject-matter jurisdiction by convicting Petitioner in 1971 under a vague first-degree murder statute
QUESTIONS PRESENTED I Whether the state trial court lacked subject-matter jurisdiction by convicting Petitioner in 1971 under a vague first-degree murder statute, MCL § 750.316, that did not define what constituted murder? II Whether People y Aaron, decided 9 years later, abrogating the first-degree felony murder doctrine, should be applied retroactively to Petitioner's conviction under Teague y Lane? Til Whether Petitioner has established his entitlement to habeas relief by invoking this Court's Original ; Jurisdiction and discretionary powers to grant the writ in aid of its appellate jurisdiction by demonstrating exceptional circumstances and where adequate relief cannot be obtained in any form or from any court? 1 * THE PARTIES The Petitioner is James Bryant, a 73 year old state prisoner serving a mandatory life sentence for firstdegree felony murder out of Wayne County, Michigan, Case #71-004908-01-FC, under the jurisdiction of the Michigan Department of Corrections, currently confined at the Saginaw Correctional Facility in Freeland, Michigan. The Respondents are the Governor Grethen Witmer, State of Michigan; Attorney General Dana Nessel; MDOC Director Heidi Washington; and Warden Thomas Winn, Saginaw Correctional Facility. 2 . Table of_Contents Questions Presented -enn rn een ewer cree e nee neens The Parties -tren enn nnn eee n nen ne 2 . Table of Cases ---n-n-ne nnn nn nnn nnn ern enene 4 Decisions Below State Court Proceedings -7 Decisions Below Federal Court Proceedings +-8 Jurisdiction -nnn e renee cence nee e ence eee n ences 9 Constitutional and Statutory Provisions Involved -9