People of Michigan v. Bryant Rector, 352619

Collision between Bryant Rector and Justin Woodard at an intersection treated as a four-way stop during a power outage; both drivers exited to inspect damage.
After a cordial exchange, Rector returned to his vehicle; as Woodard walked back to his car with his back turned, Rector accelerated and struck Woodard from behind.
Woodard was rendered unconscious and suffered a head wound; Rector left the scene briefly but later returned and admitted hitting Woodard, claiming he feared a robbery.
Rector was tried by jury and convicted of assault with intent to do great bodily harm (MCL 750.84).
On appeal Rector argued (1) insufficient evidence of specific intent to cause great bodily harm and (2) ineffective assistance because counsel did not request a self-defense instruction; he also sought a Ginther hearing.
The Court of Appeals affirmed the conviction and denied remand for a Ginther hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence that Rector intended to cause great bodily harm	State: Evidence (acceleration, witness hearing engine rev, pause after impact, damage pattern) supports inference of specific intent	Rector: Encounter was cordial; he feared robbery and struck Woodard accidentally while fleeing	Affirmed — viewing evidence in prosecution's favor a rational jury could infer intent to hit and to cause great bodily harm
Ineffective assistance for failure to request self-defense instruction	State: Counsel reasonably pursued accident defense; Rector’s testimony did not support a self-defense instruction	Rector: Counsel was deficient for not requesting self-defense instruction, which might have led to acquittal	Affirmed — counsel’s strategy to pursue accident defense was reasonable and Rector failed to show prejudice
Request to remand for a Ginther hearing	State: No further factual development would aid the claim	Rector: A Ginther hearing could develop facts showing deficient performance	Denied — record did not suggest further factual development would advance the claim

People v Parcha, 227 Mich App 236 (1997) (elements of assault with intent to do great bodily harm)
People v Carines, 460 Mich 750 (1999) (circumstantial evidence and inferences may satisfy elements beyond a reasonable doubt)
People v Harverson, 291 Mich App 171 (2010) (minimal circumstantial evidence can show specific intent)
People v Hawkins, 245 Mich App 439 (2001) (intent may be inferred from defendant’s acts, means, or manner employed)
People v Randolph, 502 Mich 1 (2018) (two-prong ineffective-assistance standard: deficient performance and prejudice)
People v Vaughn, 491 Mich 642 (2012) (reasonableness of counsel judged under wide range of competent assistance)
People v Solmonson, 261 Mich App 657 (2004) (presumption that counsel’s performance was effective; burden on defendant)
People v Rockey, 237 Mich App 74 (1999) (deference to counsel’s trial strategy decisions)
People v Heflin, 434 Mich 482 (1990) (self-defense requires intentional action justified by imminent danger)
People v Ginther, 390 Mich 436 (1973) (procedure for evidentiary hearing on claim of ineffective assistance)