People of Michigan v. Chauncey Terrell Davis
328734
| Mich. Ct. App. | Dec 22, 2016Background
- Defendant Chauncey Terrell Davis convicted by jury of conspiracy to commit armed robbery and armed robbery; sentenced to 110 months–16 years on each count.
- Prosecution introduced evidence about an earlier June 7, 2014 robbery (of which defendant had been acquitted) to show a common plan, scheme, or system related to the June 14, 2014 charged robberies.
- Common features: victims lured under pretext of buying electronics/used phones, arranged meetings at same dimly lit apartment location, and a co-actor (defendant’s cousin) appeared with a weapon to rob the buyers.
- A witness (Mohaned Salim) gave unresponsive testimony alleging defendant posted sexual solicitations for Salim’s minor children on Craigslist and referenced defendant’s jail calls; defense did not timely object to those statements.
- Trial court gave limiting and curative instructions about other-acts evidence and unresponsive testimony; defendant raised evidentiary and due-process challenges on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of June 7 other-acts evidence under MRE 404(b)/401/403 | Evidence offered for nonpropensity purpose: to show common plan/scheme/system; relevant and probative | Evidence irrelevant, unfairly prejudicial, and should be excluded; prior acquittal bars use | Affirmed: other-acts admissible to show common plan; probative value not substantially outweighed by prejudice; limiting instruction given |
| Use of evidence despite prior acquittal | Prior acquittal does not negate substantive value of testimony for identity/scheme | Acquittal should prevent use or require jury instruction on acquittal | Affirmed: prior acquittal irrelevant to admissibility; no instruction on acquittal required; Oliphant controls |
| Unresponsive testimony by Salim (Craigslist sexual posts, jail calls) — admissibility and prejudice | Testimony was relevant to witness credibility and relationship; prosecutor did not solicit the volunteered content | Testimony irrelevant, highly prejudicial, painted defendant as child trafficker and criminal | Affirmed: issue unpreserved; plain-error review fails because curative/limiting instructions given, repeated references to incarceration were unchallenged, and untainted evidence was strong |
| Whether cumulative unchallenged references to incarceration and other-acts denied due process/fair trial | Jury instructions and limiting instruction mitigated prejudice; jurors presumed to follow instructions | Due-process violation: prejudicial character evidence and unresponsive testimony denied fair trial | Affirmed: no plain error; defendant not shown prejudice affecting outcome |
Key Cases Cited
- People v. Douglas, 496 Mich 557 (discussing requirement to specify same ground for objection to preserve evidentiary issues)
- People v. Knox, 469 Mich 502 (timeliness of objections and plain-error review for unpreserved evidentiary rulings)
- People v. Sabin, 463 Mich 43 (other-acts similarity and common plan/scheme analysis)
- People v. Oliphant, 399 Mich 472 (use of other-acts evidence despite acquittal; caution on jury confusion)
- People v. Kowalski, 489 Mich 488 (plain-error standard and prejudice requirement)
- People v. Bynum, 496 Mich 610 (abuse of discretion standard for evidentiary rulings)