People of Michigan v. Dejhan Quenzelle Sanders
351798
| Mich. Ct. App. | Jun 24, 2021Background
- Defendant Dejhan Sanders was convicted by a jury of two counts of first‑degree criminal sexual conduct (CSC‑I), first‑degree home invasion, resisting arrest, and aggravated stalking; sentenced as a second‑offense habitual offender to lengthy prison terms.
- The victim (former partner; three children together) testified that Sanders repeatedly broke into her home, violated a no‑contact/protection order, and sexually assaulted her on December 6, 2018; she had memory difficulties but a body‑camera interview described two distinct assaults.
- Police observed Sanders leaving the apartment via a window; officers chased, subdued, and arrested him after physical resistance; he was transported to a hospital where officers’ body‑cam showed suicidal statements and profanities.
- Defendant testified he was invited to care for children, denied sexual assault, and denied suicidal statements; rebuttal hospital video impeached portions of his testimony.
- Trial evidence included the victim’s testimony, interviewing‑officer body‑cam, hospital body‑cam, and photographs of prior domestic‑violence injuries from November 2018; the jury convicted and the court imposed sentencing guideline scores.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for two CSC‑I counts | People: victim’s refreshed memory and body‑cam described two separate assaults; sufficient for two counts | Sanders: victim at trial said "only once," so evidence insufficient for two convictions | Held: Affirmed — viewing evidence in prosecution's favor, a rational jury could find two assaults |
| Verdict against great weight | People: evidence, including video and testimony, supported convictions | Sanders: inconsistencies, preliminary‑exam testimony, and alleged immunity/court error render verdict against weight of evidence | Held: Unpreserved; plain‑error review fails — no miscarriage of justice or clear error |
| Newly discovered evidence (unsubpoenaed witnesses) | People: Sanders knew of witnesses before trial, so evidence not newly discovered | Sanders: counsel failed to subpoena two favorable witnesses, entitling new trial | Held: Denied — witnesses were known pretrial, not newly discovered |
| Admission of hospital body‑cam (rebuttal) | People: probative impeachment of defendant’s testimony; fair rebuttal | Sanders: prejudicial and not disclosed before trial | Held: Admissible — impeachment value outweighs prejudice; defendant had actual knowledge of conduct |
| Admission of prior domestic‑violence photos/ testimony | People: admissible under MCL 768.27b to show pattern/history | Sanders: unfairly prejudicial; accused of acts not charged | Held: Admissible — relevant to history of domestic violence and not unduly prejudicial |
| Juror bias | People: juror stated she could be fair and had not heard evidence; counsel accepted jury | Sanders: juror had prior police contact and bias | Held: Waived or not established — juror competent to be fair |
| Ineffective assistance of counsel | People: record shows counsel acted strategically; no Ginther hearing; claims not supported on record | Sanders: counsel unprepared, ignored letters, failed to subpoena/ object | Held: Denied — claims unpreserved and not shown by the record |
| Substitution of counsel | People: any breakdown was defendant‑caused; defendant wanted attorney to continue; no prejudice | Sanders: counsel said he was afraid and should be replaced | Held: No abuse of discretion — court reasonably denied substitution |
| DNA testing / Brady | People: prosecution had no exculpatory DNA and was not obligated to test defendant’s clothing | Sanders: lack of DNA testing deprived him of a fair trial | Held: No Brady violation — no evidence prosecution possessed exculpatory DNA |
| Pretrial release/bond denial | People: clear and convincing evidence defendant posed danger (serious charges, prior violations, 2,028 jail calls to victim) | Sanders: should have been released on personal recognizance under MCR 6.004(C) | Held: Denial upheld — court not firmly convinced it erred |
| Sentencing scoring (OVs, PRVs) | People: OVs 4, 10, 19 and PRVs supported by record; PRV1 not relied on | Sanders: challenges to OV4 (no treatment), OV10 (no exploitation), OV19 (no officer injury), PRV1 scoring | Held: Scores not clearly erroneous; OV4/OV10/OV19 properly assessed; PRV1 not used in calculation |
Key Cases Cited
- People v. Meissner, 294 Mich. App. 438 (2011) (standard for sufficiency review).
- People v. Wolfe, 440 Mich. 508 (1992) (deference to jury on credibility).
- People v. Yost, 468 Mich. 122 (2003) (resolving conflicting evidence lies with trier of fact).
- People v. Cameron, 291 Mich. App. 599 (2011) (great‑weight review and admissibility of prior domestic acts).
- People v. Carines, 460 Mich. 750 (1999) (plain‑error standard).
- People v. Grissom, 492 Mich. 296 (2012) (newly discovered evidence standard).
- People v. Blackston, 481 Mich. 451 (2008) (MRE 403: probative vs. prejudicial).
- People v. Mills, 450 Mich. 61 (1995) (unfair prejudice definition).
- People v. Fields, 450 Mich. 94 (1995) (prosecution may rebut defendant testimony).
- People v. Buie, 298 Mich. App. 50 (2012) (substitution of counsel; breakdown standard).
- People v. Hardy, 494 Mich. 430 (2013) (sentencing‑guidelines review standard).
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor's duty to disclose material exculpatory evidence).