People of Michigan v. Arthur Lee Williams
329704
| Mich. Ct. App. | Jan 19, 2017Background
- Defendant Arthur Lee Williams was convicted by a jury of assault with intent to do great bodily harm less than murder, carrying a deadly weapon with unlawful intent, felon in possession of a firearm, and three counts of felony-firearm; sentenced as a fourth habitual offender to concurrent 10–20 year terms plus consecutive two-year felony-firearm terms.
- The incident: an early-morning altercation at a Speedway gas station where several men fought and gunfire followed; victim Demarcus Williams was shot in the leg.
- Witnesses placed defendant at the scene wearing a black hoodie and white shorts and testified he had what looked like a gun in his hoodie pocket before the fight began.
- Defendant stipulated he was a felon and therefore not legally permitted to possess a firearm.
- At trial defendant requested a jury instruction on self-defense; the trial court denied the instruction, concluding the evidence did not establish the elements necessary to permit a self-defense claim by a felon in possession of a firearm.
- Defendant appealed, arguing denial of the self-defense instruction violated due process and his right to a jury trial; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a felon may assert self-defense when charged with illegal possession and use of a firearm | The prosecution argued evidence did not permit a reasonable jury to find possession and use were justified by an honest, reasonable belief in imminent deadly force | Defendant argued he acted in defense of himself/others and thus was entitled to a self-defense instruction despite felon-in-possession stipulation | Court: A felon can assert self-defense, but here evidence was insufficient to support giving the instruction; trial court did not abuse discretion |
| Whether timing and manner of possession can justify possession for self-defense | Prosecution: Defendant had the gun before any apparent threat, undermining a claim possession was only to respond to an imminent threat | Defendant: Impliedly argued possession was connected to the emergency at the scene (necessity) | Court: Temporal relation matters; defendant had the gun in advance, so no evidence he acquired it only to meet an imminent threat |
| Whether defendant reasonably believed deadly force was necessary | Prosecution: No evidence defendant or others were under imminent threat; no testimony defendant was attacked or thought rescue was necessary | Defendant: Claimed belief in necessity of force (implicit) | Court: No evidence a reasonably prudent person would view firing into a group as necessary; nonlethal alternatives existed; self-defense not supported |
| Whether credibility attacks on prosecution witnesses affect the instruction issue | Prosecution: Witness credibility is for the jury; attacks do not create entitlement to instruction absent evidentiary support | Defendant: Argued witnesses were not credible, implying self-defense evidence existed if credibility discounted | Court: Credibility is for the factfinder; defendant failed to show evidence that would have required an instruction regardless of credibility disputes |
Key Cases Cited
- People v Dobek, 274 Mich App 58 (procedure for reviewing jury instruction applicability)
- People v Lane, 308 Mich App 38 (abuse-of-discretion standard for instruction applicability)
- People v Guajardo, 300 Mich App 26 (felon may assert self-defense; timing and manner of possession relevant to justification)
- People v Vaughn, 186 Mich App 376 (credibility determinations belong to the factfinder)