People of Michigan v. Jason Darwin Youngs Sr
328969
| Mich. Ct. App. | Jan 31, 2017Background
- Defendant Jason Youngs was convicted by a jury of first-degree home invasion and unarmed robbery for breaking into Robert Lacina’s home on October 27, 2014, assaulting Lacina when he returned, then fleeing in a red truck.
- Prosecution theory: Youngs conspired with Jamie Rummell (his ex and Lacina’s employee) who misled Lacina while Youngs burglarized the home; Rummell testified pursuant to a plea agreement.
- Key evidence included texts and truck-location inquiries, parole officer Brian Stevens’s testimony about Youngs’s post-offense behavior (no cell phone, truck not present, absconding), and jailhouse testimony from Lakendrik Willis that Youngs confessed and described steps to avoid detection.
- Defense suggested Lacina colluded with Rummell to stage an insurance claim and that Willis and others were fabricating blame; defendant was acquitted on a separate breaking-and-entering count.
- At sentencing Youngs was treated as a fourth-offense habitual offender and received consecutive terms (200–500 months and 140–500 months). He appealed raising evidentiary, instructional, plea-process, sentencing, prosecutorial-misconduct, and ineffective-assistance claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of parole/incarceration evidence | Parole-officer testimony was relevant to identity, flight, and consciousness of guilt | Testimony about parole and prior incarceration was unduly prejudicial and should've been excluded under MRE 403 | Admissible: parole status was relevant to corroborate identity, explain officer contact, and show consciousness of guilt; court gave limiting instruction; no plain error |
| Ineffective assistance for failing to object to parole/prior-incarceration references | Counsel was not ineffective because testimony was admissible | Counsel should have objected to prejudicial references by multiple witnesses | No ineffective assistance: objections would be meritless and any additional references were cumulative |
| Jury instructions (mistake-of-fact and accomplice caution) | N/A for prosecution | Defense argued instructions should have been given/requested | Waived by defense agreement; on merits no instruction required—evidence did not support mistake-of-fact or that Lacina was an accomplice |
| Plea-process and right to counsel during plea decision | N/A for prosecution | Trial court forced choice: accept plea with current counsel or get new counsel but lose ability to consult new counsel about the plea | No plain error: appointed counsel remained available and adequately advised defendant; no showing a new lawyer would have obtained a better plea |
| Consecutive sentencing and basis for consecutive terms | Prosecution: consecutive terms permitted by statute for first-degree home invasion arising from same transaction | Defendant argued court abused discretion and double-counted factors already in guidelines | Affirmed: consecutive sentences permissible; court relied on defendant’s extensive recidivism and parole status—within discretion |
| Lockridge/Crosby relief for judge-found OV facts | N/A for prosecution | Youngs sought remand under Lockridge for judicial fact-finding affecting guidelines | Denied: sentencing occurred after Lockridge and Crosby remands limited to pre-Lockridge cases; record shows court likely applied Lockridge principles |
| Prosecutorial misconduct re: witness sources and victim-sympathy evidence | Prosecution: evidence and argument were proper comment on testimony and relevant to crimes and credibility | Defendant claimed prosecutor allowed false testimony, used hearsay, and appealed to sympathy | No plain error: record does not show knowing use of false testimony; injury evidence was relevant; isolated rhetoric not prejudicial |
| Ineffective assistance (failure to call/testify; cumulative errors) | N/A for prosecution | Defense claimed counsel coerced defendant not to testify and failed to preserve errors | Denied: record shows defendant knowingly waived testifying; no cumulative prejudice shown |
Key Cases Cited
- People v. Carines, 460 Mich. 750 (standard for plain error review)
- People v. Chambers, 430 Mich. 217 (consecutive sentences are exception; purpose of consecutive sentencing)
- People v. Lockridge, 498 Mich. 358 (sentencing-guidelines judicial fact-finding; advisory remedy)
- People v. Riddle, 467 Mich. 116 (instruction required only if supported by evidence)
- People v. Quinn, 440 Mich. 178 (requirements for mistake-of-fact defense)
- People v. Waclawski, 286 Mich. App. 634 (presumption jury follows limiting instructions)
- People v. Dobek, 274 Mich. App. 58 (prosecutor should not interject collateral issues beyond guilt/innocence)
- Strickland v. Washington, 466 U.S. 668 (ineffective-assistance-of-counsel standard)