People of Michigan v. Daniel Dwayne Wright
331269
| Mich. Ct. App. | Apr 27, 2017Background
- Defendant Daniel Wright and co-defendant entered a home, tied up occupants, and abducted Devonta Griggs; shots were fired and a resident (Paige) was wounded. Wright was arrested the same day.
- Multiple witnesses (Ervin, Paige, Griggs, Crosby) later identified Wright, some with and some without masks; Ervin’s ID came after a corporeal lineup the day after the offense.
- Wright initially waived counsel and sought to represent himself, but the trial court later questioned the validity of that waiver after concerning statements and mental-health history surfaced, referred him for competency evaluation, and reappointed counsel.
- A competency hearing found Wright competent and appointed counsel represented him at trial; Wright did not renew his request to self-represent.
- Wright moved to suppress Ervin’s lineup identification as unduly suggestive; the trial court denied the motion and a jury convicted Wright of armed robbery, first-degree home invasion, and unlawful imprisonment.
- On appeal Wright challenged (1) denial of his right to self-representation and (2) admission of Ervin’s lineup identification; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court improperly withdrew permission for self-representation | Court properly ensured waiver was knowing and intelligent given seriousness of right and raised concerns | Court improperly withdrew his self-representation and should have let him continue or reask sua sponte after competency finding | No abuse of discretion; withdrawal was justified by mental-health concerns and presumption against waiver |
| Whether the court had to sua sponte revisit self-representation after finding competence | Court had discretion; no authority requires sua sponte renewal absent defendant request | Court should have readdressed waiver after competency finding | No error; defendant never renewed request and silence implies acceptance of counsel |
| Whether the corporeal lineup was impermissibly suggestive and unnecessary | Identification procedure was proper and non-suggestive; pivoting witness for a full view remedied a viewing issue | Lineup was unduly suggestive (lighting/mirror/posts/escort) and likely produced misidentification | Lineup not impermissibly suggestive or unnecessary; even if error, admission was harmless given multiple independent IDs |
| Whether any identification-error was harmless beyond a reasonable doubt | Multiple independent identifications (Paige, Griggs, Crosby) supported verdict without Ervin’s ID | Ervin’s identification was crucial and tainted, so error was not harmless | Error (if any) was harmless because other witnesses identified defendant |
Key Cases Cited
- People v. Russell, 471 Mich. 182 (discussing standards for review of waiver and competency)
- People v. Williams, 470 Mich. 634 (requirements for valid waiver of counsel and MCR 6.005 compliance)
- Johnson v. Zerbst, 304 U.S. 458 (presumption against waiver of counsel)
- People v. Kurylczyk, 443 Mich. 289 (standards for reviewing eyewitness-identification admissibility)
- Neil v. Biggers, 409 U.S. 188 (factors for assessing likelihood of misidentification)
- Perry v. New Hampshire, 565 U.S. 228 (due-process limits on identification challenges and law-enforcement suggestiveness rule)
- United States v. Wade, 388 U.S. 218 (examples of impermissibly suggestive police conduct)
- People v. Miller, 482 Mich. 540 (clear-error standard for waiver-related factual findings)