People of Michigan v. Hazley Lee Coy
327809
| Mich. Ct. App. | Oct 13, 2016Background
- Defendant Hazley Lee Coy was tried by jury in Wayne Circuit Court and convicted of first-degree premeditated murder and unlawful driving away an automobile; sentenced as a fourth habitual offender to life and 76 months–20 years respectively.
- Incident occurred at a Detroit home during an altercation between defendant and the victim in the bedroom; victim struck defendant with a wooden club.
- Defendant went to the kitchen, retrieved a metal pipe, returned to the bedroom, and struck the victim with the pipe, killing the victim.
- At trial defendant testified the victim was sitting up when he struck him; earlier police interrogation stated the victim was lying on the bed. Defendant acknowledged he could have left after being struck with the club.
- Prosecutor argued the sequence (leave, retrieve pipe, return, strike) established time for a "second look" supporting premeditation; defense contested sufficiency of evidence for first-degree murder.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was evidence sufficient for first-degree premeditated murder? | Evidence showed intentional killing with time for premeditation and deliberation (defendant left, obtained pipe, returned). | Defendant claimed the evidence did not establish premeditation sufficient for first-degree murder. | Court affirmed: evidence sufficient; minimal circumstantial evidence and even a brief lapse can support premeditation. |
Key Cases Cited
- People v. Russell, 297 Mich. App. 707 (discussing standard for sufficiency review)
- People v. Lockett, 295 Mich. App. 165 (conflicts in evidence are resolved for the prosecution)
- People v. Avant, 235 Mich. App. 499 (credibility determinations are for the trier of fact)
- People v. Bennett, 290 Mich. App. 465 (elements of first-degree premeditated murder)
- People v. Taylor, 275 Mich. App. 177 (intent required for first-degree premeditated murder)
- People v. Anderson, 209 Mich. App. 527 (premeditation requires opportunity for a "second look")
- People v. Kanaan, 278 Mich. App. 594 (minimal circumstantial evidence can establish defendant's state of mind)
- People v. Meier, 47 Mich. App. 179 (a brief time lapse may suffice for premeditation)