People of Michigan v. Joseph Smith
334953
| Mich. Ct. App. | Dec 14, 2017Background
- Victim boarded defendant Joseph Smith’s vehicle after a brief interaction on June 8, 2005; later awoke facedown with defendant on top, restrained by the neck, and anally penetrated.
- Victim sustained a bump on his forehead, rectal bleeding (doctor testified could be from ruptured external hemorrhoids), and was emotionally distraught; he sought emergency care but left before discharge.
- Sexual-assault evidence collected that night was not processed until 2014; DNA from the victim’s rectal swab matched defendant’s profile in CODIS and by a warrant-obtained sample.
- At a bench trial defendant was convicted of first-degree criminal sexual conduct (MCL 750.520b(1)(f): personal injury plus force/coercion) and sentenced as a fourth habitual offender to 12–20 years.
- On appeal defendant challenged (1) exclusion of cross‑examination about the victim’s alleged history of mental illness and (2) sufficiency of the evidence as to personal injury and use of force/coercion.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Smith) | Held |
|---|---|---|---|
| Exclusion of evidence about victim’s mental-illness history | Limitation was proper because defendant offered no theory or specifics showing the illness would affect perception/credibility; trial court within discretion to exclude irrelevant/collateral matter | Excluding cross-examination about mental illness violated right to confrontation and prevented showing potential motive to fabricate or impaired perception | Court affirmed: exclusion not an abuse of discretion; evidence was not shown to be relevant, and any constitutional claim was not preserved and fails plain-error review |
| Sufficiency of evidence for “personal injury” | Medical and testimonial evidence (rectal bleeding, head pain, emotional distress) established bodily injury or mental anguish required by statute | Insufficient: medical records lacked clear signs of trauma; victim’s voluntary entry into car undercuts force/coercion | Court affirmed: evidence supported bodily injury (bleeding/head pain) and mental anguish (tears, hysterical behavior); testimony showed force/coercion (being held down, struck, escaped after struggle) |
Key Cases Cited
- People v Grant, 445 Mich 535 (discussing preservation of evidentiary objections)
- People v Carines, 460 Mich 750 (plain-error standard for unpreserved appellate constitutional claims)
- People v Canter, 197 Mich App 550 (trial court discretion to limit cross-examination on collateral credibility matters)
- People v Petrella, 424 Mich 221 (defining "mental anguish" for personal-injury element)
- People v Asevedo, 217 Mich App 393 (personal injury element satisfied if any listed definition is proven)