People of Michigan v. Henry Jermaine Johnson, 364543

Defendant Henry Jermaine Johnson was convicted by a jury of two counts of first-degree murder under both premeditated and felony-murder theories.
The prosecution’s case relied heavily on the timeline of the victims’ last sighting (via 7-Eleven security footage) and DNA evidence placing Johnson at the apartment complex.
Johnson appealed, alleging his trial counsel was ineffective for failing to adequately investigate and call key witnesses who claimed to have seen the victims alive after the crucial timeline evidence.
At a Ginther hearing, it was revealed that counsel’s investigator attempted to contact over 20 witnesses but did not prioritize those with statements most helpful to the defense and used limited investigative methods.
The trial court denied the motion for a new trial, finding counsel’s efforts reasonable; on appeal, the Court of Appeals reversed this aspect, finding the investigation and trial strategy objectively unreasonable due to lack of direction and targeted effort.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s investigation of witnesses was adequate	Counsel attempted reasonable efforts to contact witnesses	Counsel failed to adequately investigate and prioritize witnesses with helpful statements; investigation was unreasonably limited in scope and technique	Court held investigation fell below objective reasonableness due to lack of prioritization and failure to adequately attempt contact
Whether failure to call key witnesses was sound trial strategy	Not calling witnesses was reasonable if they couldn't be contacted	The failure stemmed from inadequate investigation, not a valid strategic choice, so it cannot be justified as trial strategy	Court found that failure was not based on reasonable professional judgment, making the decision to not call witnesses unreasonable
Whether the trial court properly denied the ineffective counsel claim	Counsel's performance met objective standards	The trial court erred by focusing only on counsel's decision to not call witnesses without considering the unreasonableness of the underlying investigation	Court reversed the trial court's ruling and remanded to determine if deficient performance prejudiced the outcome
Whether new trial consideration requires prejudice analysis	No need if counsel's efforts were reasonable	Prejudice analysis is necessary because counsel's performance was objectively unreasonable	Court remanded for prejudice analysis by the trial court

Strickland v. Washington, 466 US 668 (U.S. 1984) (standard for ineffective assistance of counsel claims, requiring both deficient performance and resulting prejudice)
People v. Grant, 470 Mich 477 (Mich. 2004) (trial strategy is only reasonable if based on adequate investigation)
People v. Douglas, 496 Mich 557 (Mich. 2014) (trial counsel's strategy must be supported by reasonable investigation)
People v. Trakhtenberg, 493 Mich 38 (Mich. 2012) (deficient investigation undermines trial strategy presumption)