People of Michigan v. Alex Jay Adamowicz
330612
Mich. Ct. App.Jun 22, 2017Background
- In April 2014, John Watson entered Alex Adamowicz’s apartment; an altercation ended with Adamowicz cutting Watson’s throat and Watson’s subsequent death. Adamowicz hid the body and attempted to clean blood from the apartment.
- Adamowicz continued to live in the apartment until his mother discovered the body on May 11, 2014; he later confessed to police but claimed self-defense.
- A jury convicted Adamowicz of first-degree murder (premeditation and deliberation) and the trial court sentenced him to life without parole.
- On appeal Adamowicz raised (1) ineffective assistance of counsel for failure to call a post-trauma/PTSD expert, (2) prosecutorial error regarding questions/statements about his ability to flee, (3) evidentiary errors admitting April 13 police contact evidence and a video/photo, and (4) a constitutional challenge to mandatory life without parole.
- The Court limited review to the appellate record where applicable and reviewed preserved issues de novo or unpreserved issues for plain error.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Adamowicz) | Held |
|---|---|---|---|
| Ineffective assistance for not calling expert on post-incident behavior | Counsel’s choices were sound trial strategy; no prejudice shown | Failure to call PTSD/behavior expert deprived him of a substantial defense and might have changed outcome | Denied—no factual predicate or reasonable probability of different outcome; strategy choice protected by presumption of competence |
| Prosecutorial error re questions/statements about ability to flee | Questions and inferences about flight were permissible to challenge the honesty/reasonableness of self-defense claim | Questions and closing suggestions improperly implied a duty to retreat and were prejudicial | Denied—prosecutor acted in good faith to challenge necessity; jury instructions cured any potential error; not outcome-determinative |
| Evidentiary admission of April 13 police contact, booking photo, and audio-less interview video | Evidence was admissible under MRE 404(b) and relevant to intent, knowledge, and actions after the homicide | Evidence was improper character evidence, prejudicial, and the video without audio risked misinterpretation | Denied—issues largely waived; evidence relevant to premeditation and intent; probative value not substantially outweighed by prejudice |
| Cruel and unusual punishment challenge to mandatory life without parole | Statute presumptively constitutional; life without parole upheld historically | Mandatory life without parole is unconstitutional in light of modern science and Miller rationale | Denied—Miller applies only to juvenile offenders; defendant was over 18; statute upheld |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard: deficient performance and prejudice)
- Trakhtenberg v. United States, 493 Mich. 38 (mixed questions of law and fact; standard of review for IAC)
- Hoag v. People, 460 Mich. 1 (Strickland applied in Michigan context)
- Riddle v. United States, 467 Mich. 116 (necessity as touchstone of self-defense; retreat considerations)
- Richardson v. United States, 490 Mich. 115 (limits on retreat argument and proper use of evidence to challenge reasonableness of belief)
- Carines v. People, 460 Mich. 750 (plain-error review framework)
- Miller v. Alabama, 567 U.S. 460 (mandatory life without parole unconstitutional for juvenile offenders)
- Bass v. People, 317 Mich. App. 241 (premeditation/deliberation factors include actions before and after the crime)