COA 377838 PEOPLE OF MI V ROBERT A HOLLON Opinion - Per Curiam - Unpublished 7/16/2026

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
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S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
PEOPLE OF THE STATE OF MICHIGAN,
Plaintiff-Appellee,
UNPUBLISHED
July 16, 2026
12:20 PM
v No. 377838
Oakland Circuit Court
ROBERT A. HOLLON, LC No. 2024-291294-FH
Defendant-Appellant.
Before: TREBILCOCK, P.J., and CAMERON and LIEVENSE, JJ.
TREBILCOCK, P.J. (concurring).
I agree with my colleagues that the trial court erroneously denied defendant’s motion to
exclude evidence for the reasons largely set forth in their opinion. But I write separately to state
that extending People v Meeboer (After Remand), 439 Mich 310; 484 NW2d 621 (1992), to adult,
non-sexual assault cases involving suspected domestic violence is consistent with MRE 803(4)’s
underlying rationale: “(1) the self-interested motivation to speak the truth to treating physicians in
order to receive proper medical care, and (2) the reasonable necessity of the statement to the
diagnosis and treatment of the patient.” Id. at 322. The facts of this case exemplify why.
Defendant allegedly pushed WP down a flight of stairs in their home in Southeast Michigan
in early June 2024. A few days later, WP traveled over four hours north to the Traverse City area
with a neighbor’s assistance. Within 48 hours of arriving in the area, WP experienced significant
health problems, her neighbor called 911, and an ambulance transported WP to Munson Medical
Center in Traverse City for her to receive emergency treatment for her injuries. She was eventually
transferred to Henry Ford Hospital in Detroit, but died several days after her admission.
The urgency of her medical condition, that the statements were made in the back of an
ambulance, and while receiving emergency medical care at a hospital align well with the
trustworthiness factor to be considered under Meeboer. The same would likely apply to the future
testimony of the paramedic and emergency room doctor on remand concerning why the questions
they asked that elicited identifying information from WP were reasonably necessary for the
emergent care being provided to WP and related services necessary to protect her health and
welfare once stabilized. In my view, the size and force of the person pushing another down a flight

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of stairs, the number of stairs in that flight, and the identity of the person when that person may
appear at a hospital to provide input on medical care decisions could be reasonably relevant to the
emergent care in this case. While I agree with my colleagues that the sparse record in this case is
currently insufficient to anchor the trial court’s decision, I do not hold reservations in extending
the rationale of Meeboer to this or similar cases.
For these reasons, I concur in the result only.
/s/ Christopher M. Trebilcock

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