People of Michigan v. Brett Edward Baldridge
330960
| Mich. Ct. App. | Jan 9, 2018Background
- Defendant Brett Baldridge and the victim dated; relationship ended November 2014 and victim obtained a protective order after repeated unwanted contacts and threats.
- On December 24, 2014, Baldridge entered the victim’s home while she slept, confronted her, and produced a shotgun.
- Baldridge shot the victim in the right inner thigh, severing arterial circulation; she required emergency surgery and multiple follow-up operations and suffered lasting disability and PTSD.
- Baldridge made explicit threats to kill the victim (including to the 911 operator), fired into the ceiling, and left before police arrived; he later turned himself in and acknowledged gun familiarity.
- A jury convicted Baldridge of assault with intent to commit murder (AWIM), first-degree home invasion, two counts of felony-firearm, and aggravated stalking; the trial court imposed consecutive sentences for AWIM and home invasion; sentence was affirmed on appeal after resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for AWIM (intent to kill) | Evidence (threats, use of high-velocity shotgun, statements to 911, prior threats) supports intent to kill | Shooting victim in the leg and calling 911 show lack of intent to kill | Affirmed: circumstantial evidence and threats, weapon type, and conduct supported finding of intent to kill |
| Consecutive sentences for AWIM and first-degree home invasion | Consecutive sentences appropriate given stalking, forcible entry, and shooting; court provided specific reasons | Trial court abused discretion by not giving specific reasons or considering mitigators | Affirmed: trial court gave specific, adequate reasons; not an abuse of discretion |
Key Cases Cited
- People v. Lueth, 253 Mich. App. 670 (review standard for sufficiency of the evidence)
- People v. Bennett, 290 Mich. App. 465 (view evidence in light most favorable to prosecution)
- People v. Cameron, 291 Mich. App. 599 (draw reasonable inferences and make credibility choices supporting jury verdict)
- People v. Brown, 267 Mich. App. 141 (elements of AWIM and nature of specific-intent crime)
- People v. Taylor, 422 Mich. 554 (factors for inferring intent from conduct)
- People v. Carines, 460 Mich. 750 (circumstantial evidence and inferences can prove elements)
- People v. DeLisle, 202 Mich. App. 658 (intent to kill may be inferred from use of a dangerous weapon)
- People v. Norfleet, 317 Mich. App. 649 (standard and required specificity for ordering consecutive sentences)