People of Michigan v. Christopher Andrew Canales
350536
| Mich. Ct. App. | Jul 22, 2021Background
- Victim was accosted on the street, dragged into an apartment by defendant Christopher Canales and a codefendant, beaten, had hair cut, and suffered burns to his face after an accelerant and lighter were used; police rescued the victim and arrested Canales and co-defendant.
- Canales was offered a plea (torture, 12–20 years with dismissal of other counts) which he rejected after reviewing medical records and most photographs; two photographs showing facial burns were disclosed to defense on the first day of trial.
- At trial the jury convicted Canales of torture, unarmed robbery, unlawful imprisonment, assault with intent to do great bodily harm (AWIGBH), felonious assault, and assault and battery; he was sentenced as a fourth‑offense habitual offender to lengthy terms (e.g., 50–75 years for torture; 25–37½ years on several counts).
- On appeal Canales claimed: (1) due‑process violation and prejudice from late disclosure of photographs; (2) prosecutorial and court discovery‑order violations; (3) ineffective assistance of trial counsel for discovery failures and not calling a witness (Karen Puente); and (4) sentencing error based on an inaccurate presentence investigation report (PSIR).
- The trial court conducted a Ginther evidentiary hearing, denied relief on the discovery/IAC claims, but the Court of Appeals affirmed those rulings and concluded the PSIR misstated the law (misapplied the 25‑year violent habitual minimum to multiple counts and overstated the maximum for felonious assault). The Court affirmed convictions but remanded solely for correction of the PSIR and resentencing; it found trial counsel ineffective at sentencing for failing to spot the PSIR errors, while appellate counsel had acted appropriately.
Issues
| Issue | People’s Argument | Canales’s Argument | Held |
|---|---|---|---|
| Timely disclosure of victim photographs / due process | Late delivery was inadvertent (police evidence tech), prosecution had continuing disclosure duty but no bad faith; photos were cumulative | Prosecutor withheld key burn photos until plea expired, depriving Canales of fair plea decision | No due‑process violation or prejudice; trial court’s admission of photos was not an abuse of discretion |
| Ineffective assistance — failure to ensure complete discovery before plea | Counsel reviewed medical records and most photos; no reason to know the two photos existed before trial; strategy unaffected | Counsel failed to ensure all discovery; this kept Canales from accepting plea | No IAC for trial counsel on discovery; no reasonable probability result would differ |
| Ineffective assistance — failure to call Puente as witness | Counsel attempted contact; Puente had no relevant evidence of in‑apartment events; calling her would add little | Puente would corroborate timing and Canales’s account | No IAC; decision not to call Puente was reasonable trial strategy and speculative benefit |
| Sentencing/PSIR errors and counsel performance | Prosecution agreed PSIR erred; remand appropriate to correct PSIR and resentence; appellate counsel pursued correction | PSIR misapplied 25‑year violent‑habitual minimum to multiple counts and exceeded statutory max for felonious assault; counsel failed to object | Court: PSIR contained legal errors; remand for PSIR correction and resentencing; trial counsel ineffective at sentencing for not catching errors; appellate counsel adequate |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- People v. Milbourn, 435 Mich. 630 (1990) (sentencing proportionality and presumptive reasonableness within guideline ranges)
- People v. Davie, 225 Mich. App. 592 (1997) (trial court’s discretion to fashion remedies for discovery noncompliance and balancing test)
- People v. Lampe, 327 Mich. App. 104 (2019) (PSIR purpose, presumption of accuracy, duty to correct challenged information)
- People v. Fink, 456 Mich. 449 (1998) (prosecutor’s due‑process obligation to disclose exculpatory or material evidence)
- People v. LeBlanc, 465 Mich. 575 (2002) (mixed question review for ineffective assistance claims)