People of Michigan v. Eric Joseph Williams
332779
| Mich. Ct. App. | Aug 11, 2016Background
- In 2009 a homeowner discovered a burglary; police recovered latent fingerprints from a bedroom window and submitted them to the Michigan State Police.
- The fingerprints produced no match in 2010; a database search in 2015 produced a match to Eric Williams, who was then arrested and charged with second-degree home invasion.
- Williams pleaded no-contest to the charge, then moved to withdraw his plea, alleging ineffective assistance of counsel because counsel failed to advise or move to dismiss based on prejudicial pre-arrest delay.
- The trial court granted the motion to withdraw the plea, and then orally granted Williams’s motion to dismiss the charge for prejudicial pre-arrest delay, ordering his release.
- The prosecutor appealed, arguing (1) Williams waived the issues by pleading no-contest and (2) pre-arrest delay did not cause the sort of actual and substantial prejudice required for dismissal or for an ineffective-assistance claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the no-contest plea waive pre-arrest delay and related ineffective-assistance claims? | A nolo contendere plea is tantamount to a guilty plea and generally waives issues about factual guilt. | The trial-court ruling on a post plea motion to withdraw the plea is reviewable; waiver does not bar the present motion below. | Plea waiver argument fails to defeat review of the trial court’s decision to grant withdrawal; waiver not dispositive here. |
| Was defendant prejudiced by pre-arrest delay such that due process required dismissal? | Prosecution: delay did not cause actual and substantial prejudice to Williams’s ability to defend the 2009 charge. | Williams: delay prevented concurrent sentencing and produced a higher habitual-offender exposure—constituting prejudice. | Reversed: defendant failed to show actual and substantial prejudice to his defense; delay alone insufficient for dismissal. |
| Did counsel render ineffective assistance by failing to advise/move on pre-arrest-delay grounds? | Prosecution: because delay was not a viable defense, counsel’s failure was not objectively unreasonable and did not prejudice the plea. | Williams: counsel’s omission deprived him of a basis to avoid conviction, making the plea involuntary. | Court held counsel’s performance was not deficient under circumstances; plea was knowing, voluntary, and intelligent. |
| Did the trial court abuse its discretion in permitting plea withdrawal and dismissing charges? | Prosecution: yes—both orders lacked legal support because pre-arrest delay was not prejudicial. | Williams: no—trial court found ineffective assistance and prejudicial delay. | Reversed: trial court abused its discretion in allowing withdrawal and in dismissing the charge. |
Key Cases Cited
- People v Patton, 285 Mich. App. 229 (pre-arrest delay requires actual and substantial prejudice)
- People v Adams, 232 Mich. App. 128 (investigative delay does not violate due process; speculative prejudice insufficient)
- People v New, 427 Mich. 482 (distinguishing waiver of factual-guilt claims from challenges to the authority to prosecute)
- People v Haynes, 221 Mich. App. 551 (standard for appellate review of a trial court’s grant of a motion to withdraw a plea)
- People v Cain, 238 Mich. App. 95 (prejudice must meaningfully impair the ability to defend for dismissal based on delay)