For our subscribers

Subscribers to the Criminal Defense Resource Center’s online resources, found at, have access to more than 1,800 appellate pleadings filed by SADO Attorneys in the last five years.  The brief bank is updated regularly and is open to anyone who wants to subscribe to online access.  On our site, briefs are searchable by keyword, results can be organized by relevance or date, and the pleadings can be filtered by court of filing.  Below are some of the issues presented in briefs added to our brief bank in the last few weeks. For confidentiality purposes, names of clients and witnesses have been removed.

COA 352874

Reversible error occurred when the trial court displayed its bias while questioning the prosecution’s witness and acted as a second prosecutor, depriving defendant of a fair trial. 

COA 353914

Because the inventory search of defendant’s car is not justifiable under Anderson, it needs to be justified under some other exception to the warrant requirement to be constitutional. No other exception applies to the search of defendant’s car; thus, the search was unconstitutional.

COA 360581

SORA’s mandate that defendant register as a sex offender for life, without an individualized assessment of risk or any means for him to petition for removal, constitutes cruel and/or unusual punishment in violation of the federal and state constitutions.

COA 361024

The trial court abused its discretion when it failed to grant a motion for a bill of particulars. This error both denied defendant the opportunity to sufficiently prepare his defense and ensure that defendant was protected against double jeopardy.

COA 361267

The trial court violated defendant’s speedy trial rights by incarcerating him for 29 months pretrial, including prior to the COVID-19 pandemic, without the opportunity for bond. This resulted in the prejudicial loss of key witness testimony.

COA 361665

The trial court denied defendant’s Sixth Amendment right to counsel when it denied his request for an adjournment so retained counsel could prepare for trial. This denied defendant the opportunity to present a full defense. This structural error requires reversal of defendant’s conviction. In the alternative, defendant was denied the effective assistance of counsel.

COA 362057

The evidence seized during the warrantless search of defendant’s apartment should have been suppressed as violative of the United States and Michigan Constitutions’ prohibition against unreasonable searches. In the alternative, defendant’s trial attorney was constitutionally ineffective for failing to move to suppress this evidence.

COA 362561

Defendant was deprived of his Fourth Amendment right to be free from unreasonable searches and seizure where the police conducted a stop despite lacking probable cause and reasonable suspicion to arrest and seize defendant. 

COA 362834

The trial court erred in denying the defense motion to dismiss where the circumstances of the case established entrapment.

COA 364788

It is fundamentally unfair to weigh defendant’s three prior felony convictions using both the prior record variables and again using the habitual offender enhancement.

COA 365782

Fundamental fairness should bar a sentencing court from using any prior, uncounseled juvenile adjudication to score the guidelines.

John Zevalking
Associate Editor