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People of Michigan v. Eugene Marcel Burton
370925
Mich. Ct. App.
Mar 20, 2025
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Background

  • Eugene Marcel Burton was convicted by a jury of two counts of assault with intent to murder and related firearm charges following a shooting incident near a Lansing home.
  • The shooting occurred shortly after Burton argued with another man, Edward Johnson, during a party about a prior incident involving Burton’s sister’s house.
  • Witness Larissa Ralston-School identified Burton as the shooter, stating that she saw him in the vehicle as gunshots were fired, injuring her and another individual.
  • At trial, it was revealed that Johnson (a prior witness) discussed his testimony with Ralston-School before she testified, violating a witness sequestration order.
  • Burton appealed, challenging both the admission of Ralston-School’s testimony (arguing it was tainted and unreliable) and the sufficiency of the evidence supporting his identity as the shooter.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Admission of tainted testimony Testimony is admissible; no substantial prejudice. Testimony is unreliable due to sequestration breach. No plain error; admission was proper, jury to judge credibility.
Sufficiency of the evidence Sufficient evidence supports identity and conviction. Insufficient evidence to link Burton as the shooter. Evidence was sufficient; conviction affirmed.
MRE 403 exclusion Testimony is highly probative of identity. Testimony’s unreliability outweighs probative value. Testimony's probative value outweighed prejudice.
Sequestration order violation Offered remedies (cross-examination, etc.) Exclusion is warranted for breach of order. Extreme remedy not warranted; alternative remedies offered.

Key Cases Cited

  • People v. Carines, 460 Mich 750 (plain error review standard for unpreserved issues)
  • People v. Meconi, 277 Mich App 651 (sequestration order remedies and witness exclusion as a last resort)
  • People v. Solloway, 316 Mich App 174 (credibility assessment is for the jury)
  • People v. Bass, 317 Mich App 241 (circumstantial evidence suffices for establishing identity)
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Case Details

Case Name: People of Michigan v. Eugene Marcel Burton
Court Name: Michigan Court of Appeals
Date Published: Mar 20, 2025
Docket Number: 370925
Court Abbreviation: Mich. Ct. App.