People of Michigan v. Juan Zamudio, 333290

On August 5, 2015, Juan Zamudio stabbed Jose Antonio “Tony” Chiquito multiple times at a social gathering; Tony survived serious, potentially life‑threatening injuries.
Defendant admitted stabbing Tony but claimed he acted in self‑defense after Tony attacked him; testimony conflicted about who was the initial aggressor.
At trial the prosecution played a recorded police interrogation of defendant; defense counsel expressly stated “No objection” when the video was admitted and did not object while it was played.
A jury convicted Zamudio of assault with intent to do great bodily harm less than murder (AWIGBH) and felonious assault; trial court sentenced him to concurrent prison terms.
On appeal Zamudio raised: (1) that admission of portions of the interrogation video denied him a fair trial; (2) ineffective assistance for failing to object/redact the video; and (3) that his presentence investigation report (PSIR) contained inaccuracies requiring correction.
The Court of Appeals affirmed: waiver foreclosed review of the evidentiary claim; ineffective‑assistance claim failed for lack of prejudice because the force used was excessive; and the PSIR was not shown to be inaccurate or irrelevant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of interrogation video statements	Prosecution: video properly admitted; no error	Zamudio: statements in video deprived him of a fair trial	Waived — defense counsel expressly waived objection at trial; appellate review extinguished (People v McDonald)
Ineffective assistance for failing to object/redact video	State: even if counsel erred, defendant not prejudiced	Zamudio: counsel was ineffective for not objecting / getting redaction	Denied — unpreserved; reviewed for plain record error; no prejudice shown because defendant’s multiple, life‑threatening stab wounds made self‑defense unreasonable
Availability of self‑defense under SDA	State: SDA requires honest and reasonable belief and only necessary force	Zamudio: believed deadly force necessary to prevent death from unarmed punches	Held against defendant — belief was not reasonable and force used was excessive, so SDA does not privilege conduct (MCL 780.972 principles applied)
PSIR correction	State: PSIR accurately reflects offense and differing accounts	Zamudio: PSIR misstates witness (Wedo) and omits exculpatory witness statements	Denied — defendant failed to carry burden to show inaccuracy or irrelevancy; PSIR supported by preponderance of evidence

People v McDonald, 293 Mich. App. 292 (2011) (express trial‑counsel waiver bars appellate challenge)
People v Pickens, 446 Mich. 298 (1994) (Strickland standard for ineffective assistance of counsel)
People v Grant, 470 Mich. 477 (2004) (prejudice requires reasonable probability of different outcome)
Strickland v. Washington, 466 U.S. 668 (1984) (counsel performance and prejudice test)
People v Guajardo, 300 Mich. App. 26 (2012) (SDA requires honest and reasonable belief; excessive force defeats self‑defense)
People v Lloyd, 284 Mich. App. 703 (2009) (PSIR presumed accurate; defendant bears initial burden to show inaccuracy)
People v Maben, 313 Mich. App. 545 (2015) (court must strike inaccurate/irrelevant PSIR information upon motion)