David a Maples v. State of Michigan, 160740

Maples was arrested after a bar transaction in which a third party (Murphy) sold cocaine to an undercover officer; Maples maintained he was unaware of the sale.
At a pretrial entrapment hearing (which Maples joined), Murphy testified and submitted affidavits exculpating Maples; the trial court denied the entrapment motion and a speedy-trial motion.
On the eve of trial Murphy entered a plea that barred him from testifying for Maples; Maples’s other witness (Roberts) was unavailable, and counsel incorrectly advised Maples he could still appeal a speedy-trial claim after pleading guilty; Maples pled guilty.
A Sixth Circuit habeas ruling found counsel ineffective for that advice and prejudice from the delay; Maples’s conviction was vacated and charges dismissed, and he then sued under the Wrongful Imprisonment Compensation Act (WICA).
The Court of Claims granted summary disposition for the State and the Court of Appeals affirmed, holding Murphy’s entrapment-hearing testimony was not "new evidence" under WICA and Roberts’s testimony was not proved; the Michigan Supreme Court granted relief in lieu of leave and reversed in part.
Majority: "new evidence" means evidence not presented to the trier of fact at the trial or plea hearing; Murphy’s testimony was therefore new. Dissent: "proceedings leading to conviction" includes pretrial hearings, so Murphy’s testimony was not new.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What is "new evidence" under WICA (MCL 691.1752(b))?	"New evidence" excludes only evidence presented at the plea hearing or trial (i.e., evidence presented to the trier of fact); pretrial hearings do not bar WICA relief.	"The proceedings leading to conviction" include pretrial proceedings (e.g., entrapment hearings); evidence presented there is not new.	Majority: "proceedings leading to conviction" are those that adjudicate guilt (trial or plea); evidence not presented to the trier of fact is "new." Dissent: term is broader and includes pretrial hearings.
Was Murphy’s entrapment-hearing testimony "new evidence"?	Murphy’s testimony was never presented to the trier of fact at a guilty plea or trial, so it is new and supports WICA relief.	Murphy’s testimony was presented at a pretrial entrapment hearing that led toward conviction, so it is not new.	Held: Murphy’s testimony is new evidence under WICA because it was not presented at a proceeding that adjudicated guilt.
Did Maples establish Roberts’s proposed testimony as "new evidence"?	Maples asserted Roberts would have testified exculpatorily.	State: Maples failed to provide an affidavit or offer of proof showing what Roberts would say.	Held: Maples failed to prove Roberts’s testimony; it is not before the court as "new evidence."

Maples v. Stegall, 427 F.3d 1020 (6th Cir. 2005) (habeas relief for ineffective assistance based on prejudicial delay and erroneous advice to plead guilty)
People v. D'Angelo, 401 Mich 167 (Mich. 1977) (entrapment determination is separate from guilt determination)
People v. Cress, 468 Mich 678 (Mich. 2003) (standard for newly discovered evidence in postconviction relief)
People v. Rao, 491 Mich 271 (Mich. 2012) (defendant/defense counsel awareness defeats "newly discovered" evidence claim)
Sanford v. Michigan, 506 Mich 10 (Mich. 2020) (de novo review of statutory interpretation; primary reliance on statutory text)
People v. Reed, 449 Mich 375 (Mich. 1995) (court not bound by prosecutorial concession on legal issue)