Donald Talonen won his appeal. The Michigan Court of Appeals vacated his armed robbery conviction in a published February 2025 decision, finding that his constitutional rights were violated by his own attorney. Judge Margaret Zuzich Bakker is continuing to pursue prosecution through a replacement prosecutor process that raises documented conflict of interest concerns. All ongoing allegations are unproven and the case has not been adjudicated.
Key Points
The Michigan Court of Appeals issued a published decision in February 2025 vacating Talonen’s conviction and finding constitutional violations in the original proceedings.
Wayne Crowe, the attorney whose conduct the COA found constitutionally deficient, has since been disciplined by both the Michigan Attorney Discipline Board and New York’s disciplinary authority.
Following Allegan County Prosecutor Mike Villar’s recusal, Judge Bakker selected Berrien County as a potential replacement, whose prosecutor’s office is now the employer of Myrene Koch, named in the documented People v. Loew ex parte communications alongside Bakker.
Koch’s daughter Taylor is alleged to be Bakker’s goddaughter, a direct conflict under the Michigan Code of Judicial Conduct. This claim is alleged and has not been adjudicated.
Talonen has already served time on a conviction the state’s own appellate court found was constitutionally flawed. The continued prosecution raises documented questions about judicial bias and institutional protection.
Donald Talonen won his appeal. The Michigan Court of Appeals vacated his conviction in a published decision in February 2025. The COA explicitly found that Talonen’s constitutional rights were violated when his attorney, Wayne Crowe, reported him to law enforcement for an alleged PPO violation based on an email in which Talonen expressed dissatisfaction with Crowe’s representation.
Judge Margaret Bakker is still pursuing charges.
A Case That Should Not Have Proceeded
Talonen’s original troubles began with a Judgment of Divorce he alleges was coerced through an illusory agreement: sign, and the charges would be dropped. The JOD produced no benefit to Talonen. Instead, according to the record, it locked him into a legal structure upheld by Allegan County Judges Bakker, Kengis, and Antkoviak that forced the sale of his home and prevented him from seeing his children for nearly half a decade.
The case cannot be understood without examining Wayne Crowe’s role. Retained after the JOD in hopes of untangling the prior attorney’s work, Crowe compounded the damage. His conduct produced the unconstitutional probation violation the COA ultimately struck down. Crowe has since been sanctioned by Michigan’s ADB and New York’s disciplinary authority, a rare dual consequence in a state where attorney discipline is inconsistent at best.
The appellate court’s published decision found the prosecution that sent Talonen to prison was constitutionally flawed. The attorney who built that prosecution has since been disciplined in two states. The case that remains is built on that foundation.
Prosecutor Shopping and Documented Conflicts
Following Allegan County Prosecutor Mike Villar’s recusal, citing a prior brief representation of Talonen, Judge Bakker sought a replacement prosecuting office. She identified Berrien County as a potential option.
Berrien County’s prosecutor’s office is the current employer of Myrene Koch. Koch’s involvement in the ex parte communications documented in People v. Loew, alongside Judge Bakker, is part of the public record. Koch’s daughter Taylor is alleged to be Bakker’s goddaughter. That alleged relationship, if accurate, constitutes a direct conflict under the Michigan Code of Judicial Conduct. The allegation has not been adjudicated.
Selecting a prosecutorial office with documented institutional ties to the judge and to prior conduct concerns in the same network of cases is not a neutral administrative choice. It is a selection that requires independent review before proceedings advance.
Who Is Being Protected
Beyond the procedural framing, a pattern emerges. The original case involved then-Judge Roberts Kengis and Myrene Koch, whose conduct has drawn documented scrutiny. The Allegan County Sheriff’s Office was central to the original investigation. Judge Bakker, who has close documented ties to Kengis, Koch, and Sheriff Frank Baker, is insisting on keeping the case alive against a man whose conviction the state’s appellate court has already struck down.
Continued prosecution without new evidence, without a new legal theory, and on a foundation the COA found constitutionally deficient raises a straightforward question: whether this serves justice or serves to delay scrutiny of the people and institutions involved in the original case.
When a judge with documented ties to prior misconduct actors in a case continues prosecution after an appellate reversal, the burden of justification is on the court, not the defendant.
The Record Is Clear
Talonen has already served time on a conviction the state’s appellate court found was unconstitutionally obtained. He is not asking to escape accountability. He is asking Allegan County to follow the appellate court’s ruling. Judge Bakker’s continued refusal to acknowledge the finality of that ruling, combined with a prosecutor selection process that raises conflict of interest questions, sends a documented message: appellate wins do not produce finality when the court below has institutional interests in the original outcome.
Judge Bakker should recuse herself from the Talonen case. Her documented ties to Myrene Koch and the Berrien County connection make her continued supervision of this proceeding difficult to defend as impartial.
The replacement prosecutor selection process should be reviewed by an independent authority before the case proceeds further.
A formal accounting of why prosecution continues after a published appellate finding of constitutional violations is owed to Talonen, to the public, and to the integrity of Allegan County’s court system.
How to Take Action
Community members can request that Judge Bakker issue a formal dismissal and file Judicial Tenure Commission complaints. The sample letter below may be adapted and sent to Prosecuting Attorney Mike Villar requesting an independent investigation.
Quick FAQs
What did the Michigan Court of Appeals find in the Talonen case?
In a published February 2025 decision, the COA vacated Talonen’s armed robbery conviction, finding his constitutional rights were violated when his attorney Wayne Crowe reported him for an alleged PPO violation based on an email expressing dissatisfaction with Crowe’s representation.
What happened to Wayne Crowe?
Crowe has been disciplined by both the Michigan Attorney Discipline Board and New York’s disciplinary authority, a rare dual consequence. His conduct in the Talonen matter was the basis for the COA’s finding of constitutional deficiency.
Why does the Berrien County replacement raise conflict concerns?
Berrien County’s prosecutor’s office employs Myrene Koch, who was involved in the documented People v. Loew ex parte communications alongside Judge Bakker. Koch’s daughter Taylor is alleged to be Bakker’s goddaughter, a potential direct conflict under the Michigan Code of Judicial Conduct. All conflict allegations are unproven and have not been adjudicated.
What is Clutch Justice calling for?
Bakker’s recusal from the Talonen case, independent review of the replacement prosecutor selection process, and a formal accounting of why prosecution continues after the COA’s published finding of constitutional violations in the original proceeding.
Sources
Cite This Article
Bluebook: Williams, Rita. Why Is Judge Margaret Bakker Still Pursuing Charges After a Successful Appeal?, Clutch Justice (July 24, 2025), https://clutchjustice.com/2025/07/24/why-is-judge-margaret-bakker-still-pursuing-charges-after-a-successful-appeal/.
APA 7: Williams, R. (2025, July 24). Why is judge Margaret Bakker still pursuing charges after a successful appeal? Clutch Justice. https://clutchjustice.com/2025/07/24/why-is-judge-margaret-bakker-still-pursuing-charges-after-a-successful-appeal/
MLA 9: Williams, Rita. “Why Is Judge Margaret Bakker Still Pursuing Charges After a Successful Appeal?” Clutch Justice, 24 July 2025, clutchjustice.com/2025/07/24/why-is-judge-margaret-bakker-still-pursuing-charges-after-a-successful-appeal/.
Chicago: Williams, Rita. “Why Is Judge Margaret Bakker Still Pursuing Charges After a Successful Appeal?” Clutch Justice, July 24, 2025. https://clutchjustice.com/2025/07/24/why-is-judge-margaret-bakker-still-pursuing-charges-after-a-successful-appeal/.
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