People of Michigan v. James Michael Daniels-Norris, 351222

Defendant (James Michael Daniels-Norris) faced two consolidated Calhoun Circuit Court cases: Docket No. 351221 (first-degree CSC of a victim under 13; sentenced 25–50 years) and Docket No. 351222 (two counts third-degree CSC and one count assault with intent; concurrent sentences totaling 75 months–15 years and 23 months–10 years).
Defense counsel stipulated to joinder of the two cases for trial; defendant was initially reluctant but told the court he was "okay with that" after the court explained joinder was his choice.
The TD matter (Docket No. 351221) contained overwhelming DNA evidence and an admission by defendant; the analyst gave astronomically small random-match probabilities.
The VB matter (Docket No. 351222) lacked DNA and a confession and had previously resulted in a mistrial, but VB testified to multiple instances of anal penetration.
Trial court gave a cautionary jury instruction about considering evidence of other alleged acts; both parties had no objection.
On appeal defendant claimed ineffective assistance of counsel for stipulating to joinder and advising him to agree; the Court of Appeals affirmed, finding no prejudice and no reasonable probability of a different outcome if tried separately.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel's stipulation to joinder and advising defendant to agree denied defendant effective assistance of counsel	Counsel acted reasonably; joinder appropriate; defendant cannot show a reasonable probability of a different result if tried separately	Counsel was ineffective for agreeing to joinder and advising defendant to consent	No ineffective assistance: overwhelming DNA/admission in TD case, VB testimony strong, judge would likely have admitted similar evidence separately, cautionary instruction given; no reasonable probability of different outcome; affirmed

People v. Lockett, 295 Mich. App. 165 (2012) (articulates ineffective-assistance test and standard of review)
People v. Mahone, 294 Mich. App. 208 (2011) (jurors presumed to follow instructions; instructions cure most errors)
People v. Breeding, 284 Mich. App. 471 (2009) (appellate review often unavailable for matters to which defense counsel agreed)
People v. Bosca, 310 Mich. App. 1 (2015) (no review for errors contributed to by defendant’s plan or negligence)
People v. Hoag, 460 Mich. 1 (1999) (presumption that counsel’s decisions reflect sound trial strategy)