People of the State of Michigan v. Prentice Devell Watkins

Summary

The Supreme Court of Michigan held that a defendant who pleaded guilty to open murder and later testified at a degree hearing waived the privilege against compelled self-incrimination by failing to invoke it. The court characterized the degree hearing as an extension of the plea proceeding and affirmed the defendant’s first-degree felony-murder conviction.

Holdings

1. A degree hearing following a guilty plea to open murder is an extension of the plea hearing, and the trial court may question the defendant as necessary to determine whether the offense is first- or second-degree murder under M.C.L. § 750.318.
2. The privilege against compelled self-incrimination is not self-executing; because Watkins answered the court's questions without invoking the privilege, he waived it and could not later claim that the questioning constituted error.

Questions Presented

1. Whether the trial court could question the defendant at a degree hearing held after the defendant pleaded guilty to open murder.
2. Whether the defendant waived the privilege against compelled self-incrimination by answering the court's questions without asserting the privilege.

Disposition

affirmed