People of Michigan v. Gregory Pierre Matthews, 331177

Background

On Sept. 28, 2014, William Kirkland (wearing a white shirt) was robbed at gunpoint; he threw a Rolex and Cartier glasses to the ground and the robber (described in black clothing) left in a gray minivan. Defendant Gregory Matthews was later arrested and convicted by a jury of armed robbery, felon-in-possession, and felony-firearm.
Defendant claimed an alibi: two witnesses (his mother and Diana Babaan) would place him at his mother’s house that morning, but he did not disclose them to defense counsel until four days before trial despite knowing them since the date of the offense.
The trial court excluded the alibi witnesses under MCL 768.20/768.21 for untimely notice; defendant did not request a continuance.
At trial, the victim identified defendant in a photo array; three neighbors corroborated seeing a man in black pointing a gun at a man in white. Defendant attempted to hide when arrested and later said he had “just fucked up so bad.”
Defendant appealed, raising (1) exclusion of alibi witnesses / right to present a defense, (2) verdict against the great weight of the evidence, (3) insufficiency of bindover and related ineffective assistance claims, (4) sentencing/Lockridge argument, and (5) multiple ineffective-assistance claims in a Standard 4 brief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of untimely alibi witnesses	Prosecution: exclusion was proper under MCL 768.20/768.21; prejudice from late disclosure	Matthews: exclusion deprived him of his right to present a defense	Affirmed — court did not abuse discretion; statutory notice is reasonable and exclusion not unconstitutional here (prejudice to prosecutor, no good reason for delay).
Right to present a defense (constitutional challenge)	State: procedural rule (MCL 768.20) is a reasonable condition and not arbitrary	Matthews: exclusion violated his constitutional right to present a defense	Held no plain constitutional error; rule is not arbitrary/disproportionate given facts.
Verdict against great weight of the evidence	State: multiple witnesses corroborated robbery; credibility for jury	Matthews: victim incredible, missing physical items, motive to lie	Held no plain error; testimony not patently incredible and other evidence supported conviction.
Bindover sufficiency / related ineffective assistance	State: conviction at trial cures any bindover insufficiency; counsel not ineffective for not moving to quash	Matthews: preliminary exam lacked admissible evidence; counsel ineffective for not appealing/quashing	Held defendant fairly convicted so bindover challenge barred; counsel not ineffective because any challenge would be futile.
Sentencing under Lockridge	State: Lockridge review applies to departure sentences; defendant’s minimum sentence was within guidelines	Matthews: sentence unreasonable under Lockridge	Held Lockridge reasonableness review inapplicable; MCL 769.34(10) controls and sentence affirmed.
Multiple ineffective-assistance claims (Standard 4 brief)	State: record shows no deficient performance causing prejudice	Matthews: various failures (complaint, discovery, alibi notice, PRV scoring, counsel absence)	Held claims fail on record: most allegations lack factual predicate, would have been futile, or defendant caused the late alibi disclosure; no cumulative error.

Key Cases Cited

People v Travis, 443 Mich. 668 (1993) (factors for evaluating exclusion of undisclosed alibi witnesses)
People v Merritt, 396 Mich. 67 (1976) (preclusion an extreme sanction; limited to egregious cases)
Taylor v. Illinois, 484 U.S. 400 (1988) (defendant’s duty of candor to counsel; upholding disclosure rules)
Chambers v. Mississippi, 410 U.S. 284 (1973) (right to present a defense balanced against procedural rules)
People v Carines, 460 Mich. 750 (1999) (plain-error review for unpreserved constitutional claims)
People v Lockridge, 498 Mich. 358 (2015) (reasonableness review applies to departure sentences — MCL 769.34(10) unaffected)