People of Michigan v. Jamon Niquan Lee Hampton
329114
| Mich. Ct. App. | Nov 15, 2016Background
- On June 25, 2013, Jamon Hampton and his brother Valentino Stewart went to confront a person; Hampton carried an AR-15 supplied by Mark Williams. Williams later testified he removed the safety after Hampton asked.
- Shots were fired; Anthony Kye (an unrelated bystander) was killed and Michelle Waters was struck; Hampton was tried for that shooting.
- A jury convicted Hampton of second-degree murder, assault with intent to commit murder, carrying a dangerous weapon with unlawful intent, and felony firearm. Sentences: 400–880 months (murder), 225–880 months (assault), 22–60 months (weapon), and 2 years (felony firearm).
- On appeal Hampton argued (1) the prosecutor improperly vouched for and bolstered Williams’ credibility and improperly appealed to sympathy for the victim’s family during closing argument, and (2) his sentences for murder and assault were disproportionate/unreasonable and he was entitled to resentencing.
- The Court of Appeals reviewed the unpreserved prosecutorial-misconduct claim for plain error and reviewed sentencing issues under governing precedent and MCL 769.34(10).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prosecutorial misconduct — vouching and victim-sympathy in closing | Prosecutor argued Williams’ return from Mississippi and exposure to a long sentence supported his credibility; mentioned victim’s family awaiting justice. | Hampton said these comments improperly vouched for the witness and appealed to jury sympathy, denying a fair trial. | No error: remarks constituted permissible argument from evidence (no special-knowledge vouching); the family reference was isolated/noninflammatory and jury instructions cured any risk. |
| Sentencing proportionality / resentencing after Lockridge | State contended sentences were within guidelines and MCL 769.34(10) requires affirmance absent scoring error or reliance on inaccurate info. | Hampton argued minimum sentences were unreasonable/disproportionate given his background and life circumstances and sought resentencing. | Affirmed: sentences fell within guidelines and no scoring/inaccurate-info claim; thus MCL 769.34(10) mandates affirmance. Even on proportionality review, no unusual circumstances shown. |
Key Cases Cited
- People v Bahoda, 448 Mich 261 (prosecutor may not vouch with special-knowledge statements)
- People v Dobek, 274 Mich App 58 (prosecutor has wide latitude to argue witness credibility from the evidence)
- People v Watson, 245 Mich App 572 (contextual review of victim-sympathy remarks; isolated references may be permissible)
- People v Lockridge, 498 Mich 358 (reasonableness review for departures from guidelines)
- People v Schrauben, 314 Mich App 181 (MCL 769.34(10) remains binding post-Lockridge)
