People of Michigan v. Chad Martin Purcey, 330877

Background

Defendant and victim were involved in an altercation in the defendant’s second-floor bedroom after a dispute over pooled money for food; the bedroom door ended up off its hinges.
Victim testified defendant grabbed a 16-inch knife and attempted to stab him; victim suffered serious finger injuries when he grabbed the blade.
Defendant gave a recorded jailhouse interview claiming the three brothers forced the door in, he felt threatened in his room, and grabbed a knife "just in case;" he did not testify at trial.
A jury convicted defendant of assault with intent to do great bodily harm less than murder (AWIGBH).
Trial court refused defendant’s requested jury instruction on self-defense because defendant did not testify; later denied a new-trial motion, holding the evidence could not support an honest and reasonable belief of imminent great bodily harm and that any error was harmless.
The Court of Appeals reversed and remanded for a new trial, finding the trial court erred in refusing the instruction and that the error was not harmless.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a self-defense instruction was required	The prosecutor argued the evidence did not support an honest and reasonable belief of imminent death or great bodily harm.	Defendant argued his recorded statement provided sufficient evidence on all elements of self-defense even though he did not testify.	Court held the instruction was required because evidence supported all elements and a jury could reasonably find self-defense.
Whether defendant had to testify to obtain a self-defense instruction	Court below treated lack of testimony as reason to deny instruction.	Defendant relied on precedent that a defendant need not testify to obtain a self-defense instruction.	Court held defendant need not testify to merit a self-defense instruction (trial court erred).
Whether exclusion of the self-defense instruction was harmless	Prosecution contended any error was harmless because jury convicted of the greater AWIGBH offense, not a lesser-included offense.	Defendant argued the missing instruction undermined the verdict because it was his sole defense and evidence supported it.	Court held the error was not harmless; excluding the defense was outcome determinative and undermined verdict reliability.
Whether denial of new trial was an abuse of discretion	Trial court found insufficient evidence for self-defense and denied new trial.	Defendant argued the court abused its discretion by denying new trial after acknowledging the initial legal error.	Court held denial of new trial was an abuse of discretion and remanded for new trial.

Key Cases Cited

People v Hoskins, 403 Mich 95 (1978) (defendant need not testify to merit self-defense instruction)
People v McGhee, 268 Mich App 600 (2005) (standard of review for instructional and constitutional claims)
People v Gillis, 474 Mich 105 (2006) (trial court abuse-of-discretion review for whether an instruction applies)
People v Powell, 303 Mich App 271 (2013) (review of trial court’s decision on new-trial motions)
People v Unger, 278 Mich App 210 (2008) (abuse of discretion standard explained)
People v Dupree, 486 Mich 693 (2010) (self-defense as an affirmative defense and burden to show prejudice from instructional error)
People v Guajardo, 300 Mich App 26 (2013) (defendant must produce some evidence on all elements to require instruction)
People v Wess, 235 Mich App 241 (1999) (jury must be instructed on defenses supported by evidence)
People v Rodriguez, 463 Mich 466 (2000) (standard for harmless-error analysis for preserved nonconstitutional errors)