People of Michigan v. Elamin Muhammad
326 Mich. App. 40
Mich. Ct. App.2018Background
- Defendant Elamin Muhammad was convicted after a bench trial of armed robbery and felony-firearm (second offense); sentenced as a fourth-offense habitual offender. Trial court admitted STRmix probabilistic genotyping DNA results and denied suppression of a shoe/insole recovered at the scene.
- A shoe insole found at the robbery scene contained a low-level, degraded mixed-DNA profile; Mitotyping analyst Holland developed the profile and Dr. John Buckleton performed statistical interpretation using STRmix, producing a likelihood that someone other than Muhammad contributed DNA of about 1 in 100 billion.
- Defense challenged STRmix under Daubert/MRE 702; the court held a pretrial evidentiary (Daubert) hearing with experts for both sides and admitted STRmix evidence, incorporating the Daubert hearing testimony at trial.
- The court found STRmix had undergone validation testing, peer review, adoption/approval by forensic bodies, and use in multiple jurisdictions; a coding error discovered elsewhere affected only very complex (3+ donor) mixtures and not this case.
- Defense also sought suppression/authentication challenges to the shoe/insole (claiming contamination and handling errors); the court held those issues affected weight, not admissibility, and authenticated the evidence under MRE 901.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of STRmix probabilistic genotyping under MRE 702/Daubert | STRmix is reliable: validated, peer-reviewed, used by labs and commissions, based on MCMC methods; assists trier of fact | STRmix is novel/unreliable for field mixtures, has potential errors and lacks established error rates; therefore inadmissible | Court admitted STRmix; no abuse of discretion—Daubert factors (testing, peer review, error rate, standards, acceptance) supported reliability |
| Authentication and contamination of shoe/insole | Shoe and insole properly preserved, chain shown; evidence admissible | Detective handling contaminated or degraded insole; evidence should be suppressed or discounted | Court denied suppression; gaps/handling go to weight, not admissibility; MRE 901 satisfied |
| Sufficiency of evidence to convict (identity issue) | DNA, surveillance, clothing/cigarettes, texts and recorded calls, flight from scene establish identity | Identification unreliable (masked perpetrator); challenges to DNA and other evidence | Convictions affirmed; viewed in light most favorable to prosecution, evidence sufficient to prove elements beyond reasonable doubt |
| Ineffective assistance of counsel (failure to pursue alibi, DNA strategy, disclosure) | Counsel failed to investigate/present alibi, mishandled DNA challenges, missed exculpatory e-mail (Brady) | Counsel investigated alibi, pursued Daubert hearing and cross-examination, e-mail not material; choices were reasonable strategy | Court found counsel not ineffective: strategic choices supported, Brady not shown because e-mail was cumulative/nonmaterial |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., 509 U.S. 579 (gatekeeping factors for scientific evidence)
- Gilbert v. DaimlerChrysler Corp., 470 Mich. 749 (MRE 702 federal incorporation and gatekeeper role)
- People v. Bynum, 496 Mich. 610 (abuse of discretion standard for evidentiary rulings)
- People v. Stevens, 306 Mich. App. 620 (deference to factfinder on witness credibility)
- People v. Chambers, 277 Mich. App. 1 (elements of armed robbery)
- People v. Hutner, 209 Mich. App. 280 (bench-trial sufficiency standard)
- People v. LeBlanc, 465 Mich. 575 (standards for ineffective assistance review)