What Is Manifest Injustice in a Michigan 6.500 Motion?
- Jacob Steenholdt
- 2 days ago
- 6 min read
In Michigan, the phrase “manifest injustice” represents a powerful legal principle. It's the doorway to correcting some of the most serious wrongs that can occur in the criminal justice system. It's what the courts look for when a conviction or a plea defies basic fairness. When the result simply can't stand without shaking confidence in justice itself.
Many people file a Michigan 6.500 motion for relief from judgment under Michigan Court Rules (MCR 6.500). Proving manifest injustice is at the heart of these cases, and it’s often what determines whether a conviction can be reopened or corrected.
It can also fix an attorney's error that changed the course of someone's life. Mark Linton, a prominent Michigan appellate attorney with vast experience in 6500 motions and Michigan criminal appeals, explains everything.
The Doctrine of Manifest Injustice Under Michigan 6.500 Motions
According to Michigan appellate courts, manifest injustice is an error or irregularity that undermines the fundamental fairness of the proceeding.
It's not synonymous with mere error, procedural irregularity, or harmless oversight. It's essentially an outcome that is plainly unfair, shocking to conscience, or inconsistent with the rudimentary demands of justice.
The Michigan Supreme Court, in the People v. Carines (1999) case, provides more insight. It explained that manifest injustice results when an erroneous or omitted instruction pertains to a controlling or basic issue of the case.
And that error seriously affects the fairness, integrity, or public reputation of judicial proceedings. The People v. Swirles (1996) case goes further with the definition.
In this case, the Court of Appeals held that manifest injustice exists where the record shows one of three things. Either a plea was involuntary, or unknowing, or the defendant was denied effective assistance of counsel.
The Michigan manifest injustice standard, under these precedents, operates as a safety valve. It allows courts to correct fundamental errors even where procedural defaults might otherwise bar review.
This is the standard judges apply when deciding whether a Michigan 6,500 motion should reopen a conviction.
How Michigan 6,500 Motions Define Good Cause and Actual Prejudice
In many Michigan 6.500 motions, manifest injustice may independently justify relief. However, it’s often discussed in conjunction with the twin requirements of good cause and actual prejudice under MCR 6.508(D).
Good cause refers to a legitimate reason for failing to raise an issue earlier in a case. This reason could be ineffective assistance of counsel, newly discovered evidence, or changes in the law. Demonstrating good cause is essential to move a Michigan 6,500 motion past the court’s procedural gatekeeping.
Actual prejudice requires showing that the error likely affected the outcome of the proceedings. In practice, courts ask whether the error likely changed the result—and if so, a Michigan 6.500 motion can succeed.
When a defendant demonstrates manifest injustice in a conviction, Michigan courts may occasionally treat it as having satisfied the prejudice treatment.
For instance, in the People v. Cole (2012) case, the Michigan Supreme Court held that the underlying defect in a case may undermine the validity of a plea itself. And in such cases, relief may be warranted to prevent manifest injustice even if procedural hurdles exist.
Common Grounds for Manifest Injustice in Michigan 6.500 Motions
Each case turns on its own facts. However, Michigan courts have identified recurring categories of post-conviction claims that may constitute manifest injustice. These include:
Involuntary or Unknowing Pleas
A plea that's not made voluntarily, knowingly, and understandingly violates MCR 6.302(A) and the Due Process Clause. The Michigan Supreme Court emphasizes that a valid plea requires a full understanding of its direct consequences.
These consequences include the maximum possible prison sentence and mandatory minimums, including lifetime parole supervision. Failure to inform the defendant of such consequences renders the plea involuntary.
And the failure warrants relief to prevent manifest injustice despite procedural roadblocks under MCR 6.508(D).
Ineffective Assistance of Counsel
Claims of ineffective assistance of counsel frequently serve as the basis for 6.500 motions alleging manifest injustice. And the governing standard remains well articulated in the Strickland v. Washington (1984) case.
And it was adopted in the People v. Pickens (1994) case. It says that the counsel's performance fell below an objective standard of reasonableness. And there's a reasonable probability that, but for counsel's error, the result of the proceeding would have been different.
Michigan appellate decisions like the People v. Douglas (2012) and Lafler v. Cooper (2012) cases illustrate successful 6.500 claims grounded in counsel's ineffectiveness. This includes failure to investigate, failure to present exculpatory witnesses, or failure to communicate plea offers.
When ineffective assistance infects the plea process, the resulting conviction is deemed fundamentally unreliable. And courts often grant relief to prevent manifest injustice. This is especially the case when the deficient performance affects the defendant's decision to plead guilty rather than proceed to trial.
Newly Discovered Evidence
Michigan courts also recognize manifest injustice where new evidence emerges. That's if the evidence would likely have produced a different result if presented at trial. Under the People v. Cress (2003) case, a defendant must show four things.
First, the evidence itself must be newly discovered, not merely newly available. Secondly, it's not cumulative. Thirdly, it'd probably lead to a different outcome on retrial. Lastly, the defendant exercised reasonable diligence in discovering it.
This standard applies both on direct appeal and in post-conviction settings. New evidence can deeply undermine confidence in the verdict. This may be in the form of DNA exonerations or key witness recantation. And courts have found that refusal to grant relief may amount to manifest injustice.
Sentencing Errors and Jurisdictional Defects
Certain errors in sentencing and jurisdiction may also rise to the level of manifest injustice. And Michigan Compiled Laws (MCL) 769.34(10) states that a defendant may challenge a sentence that departs from the guidelines range or is based on inaccurate information.
In the People v. Francisco (2006) case, the court held that a sentence based on incorrect scoring of the guidelines constitutes plain error. And this requires re-sentencing.
Some sentencing errors are constitutional. However, they may still trigger relief under the manifest injustice standard. That's when they undermine the legitimacy of the judgment.
Procedural Limit of the One-Motion Rule and Successive Filings
The post-conviction framework imposes strict limits on repetitive filings. MCR 6.502(G) provides that “one and only one motion for relief from judgment” may be filed for absent, newly discovered evidence, or a retroactive change in the law.
Michigan courts have consistently enforced this limitation. And the People v. Ambrose case is a prime example. Here, the court held that successive motions are barred even when the defendant asserts previously unraised constitutional claims.
The only recognized exceptions appear in MCR 6.502(G)(2). And these exceptions include when the motion relies on a retroactive change in law or newly discovered evidence.
This means you must raise all available claims in the initial 6.500 motion. And strategic omission or incomplete presentation can foreclose further review. And this demonstrates the necessity of comprehensive preparation.
Federal Habeas Review Compared to Michigan 6.500 Motions
The concept of manifest injustice in Michigan post-conviction practice parallels the “fundamental miscarriage of justice” exception. This exception is recognized in federal habeas corpus proceedings.
Under Title 28 Section 2254 of the United States Code, federal courts may excuse procedural default where a constitutional violation probably resulted in the conviction of an innocent person.
Michigan courts aren't bound by federal procedural standards. Nonetheless, they often draw upon federal jurisprudence to interpret manifest injustice in a manner consistent with due process.
The Michigan Supreme Court has acknowledged this overlap in the People v. Reed (1995) case. It noted that post-conviction remedies must remain adequate to redress foundational constitutional wrongs.
Why You Need Mark Linton When Litigating a Manifest Injustice Claim
Most 6.500 motions die on paper. And it's not because the injustice isn't real, but because the strategy isn't. Mark Linton, a top-ranking Michigan appeals lawyer, doesn't make that mistake.
He makes sure every move is deliberate, and every citation loaded. His approach is surgical. Strategic. Precise. The kind of advocacy that makes judges lean back and reconsider what they thought was settled law.
He sees the cross-examination that never happened and the plea that was never truly understood. He knows where cases cracked, where ineffective counsel stumbled, and where the system quietly forgot its duty to be fair. And he rewires the case to work for you.
f you believe a manifest injustice occurred in your Michigan 6.500 motion, or prior conviction, Contact Mark Linton today to review your case and restore fairness to. your record.