People of Michigan v. Chiram Milton Armstead
333434
Mich. Ct. App.Sep 14, 2017Background
- On July 4, 2015, Chiram Armstead and two companions broke into Eleanor Blevins’s motel room; surveillance video and a 911 call captured the attack in which the victim was beaten and strangled to death.
- Armstead was tried on alternative counts of first-degree premeditated murder and first-degree felony murder (predicated on first-degree home invasion and torture), and was convicted on both theories; the trial court later vacated the felony-murder conviction and sentenced him to life without parole on the premeditated murder conviction.
- Armstead was also convicted of first-degree home invasion and torture and received concurrent prison terms for those offenses.
- At trial, police officers identified Armstead in surveillance video and in a Facebook photo; two officers also made unsolicited references to prior contact or investigations involving Armstead.
- Defense conceded involvement in the break-in and fight but disputed premeditation and that Armstead committed the strangulation.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Armstead) | Held |
|---|---|---|---|
| Sufficiency of evidence for felony-murder | Evidence supported felony-murder as the killing occurred during forcible entry and torture | Evidence insufficient to show killing occurred during the commission of the predicate felony | Moot — felony-murder conviction vacated by trial court; no relief available |
| Admission of testimony referencing prior police contact/investigations (Officer Dabliz/Murphy) | References were brief/unresponsive and did not prejudice the jury given video evidence | Testimony unfairly implied prior criminality and deprived Armstead of a fair trial | No plain error; testimony not so prejudicial to affect substantial rights |
| Ineffective assistance for failing to object/request curative instruction | No ineffective assistance; decision not to object was trial strategy to avoid highlighting comments | Counsel was ineffective for not objecting and not seeking a limiting instruction | No — counsel’s conduct fell within reasonable trial strategy and no prejudice shown |
| Officer identification testimony (invading jury province) | Identification testimony was permissible lay-opinion helpful to jury | Officer improperly invaded jury function by identifying defendant in video/photos | Even if error, no prejudice — identity was not contested and video evidence made the point clear |
Key Cases Cited
- People v Carines, 460 Mich 750 (standard for plain-error review in criminal cases)
- People v Lane, 308 Mich App 38 (limitations on reviewing unpreserved ineffective-assistance claims)
- People v Frazier, 478 Mich 231 (Strickland-type framework for ineffective assistance in Michigan)
- People v Stanaway, 446 Mich 643 (presumption that counsel’s conduct is sound trial strategy)
- People v Unger, 278 Mich App 210 (strategic reasons counsel may avoid objecting to avoid highlighting testimony)
- People v Hackney, 183 Mich App 516 (unresponsive prosecution witness testimony ordinarily not grounds for mistrial absent prosecutor involvement)
- People v Lumsden, 168 Mich App 286 (mistrial warranted only for egregious errors not curable otherwise)
- People v Griffin, 235 Mich App 27 (isolated inappropriate references do not automatically require mistrial)
- People v Wallen, 47 Mich App 612 (distinguishing isolated vs. deliberate repeated references to prior bad acts)
- People v Drossart, 99 Mich App 66 (limits on lay witness testimony that invades the jury’s province)