People of Michigan v. Justin William Huffman, 349792

Justin Huffman was convicted by a jury of felonious assault, felon-in-possession of a weapon, felon-in-possession of ammunition, and two felony-firearm counts; some related charges were dismissed or resulted in acquittal.
Key evidence: a neighbor saw Huffman holding/pointing a long .22 rifle and heard shots; a .22 rifle was found in a car Huffman entered after fleeing; a fresh .22 casing and a bullet hole in the house exterior were recovered; Huffman had matching ammunition in his pocket; officers testified Huffman admitted firing the rifle twice.
At trial prosecutors elicited testimony that the recovered rifle was listed as stolen in LEIN and repeatedly identified Huffman’s 2016 felony convictions (including felonious assault). The prosecutor mentioned those convictions in opening statement.
Defense counsel did not object to the LEIN “stolen” testimony and did not seek a stipulation limiting disclosure of the nature of prior convictions; counsel also did not pursue rehabilitation questions for family witnesses who denied seeing a gun or hearing shots.
Huffman appealed claiming ineffective assistance of counsel on those three grounds and raised cumulative-error arguments; the Court of Appeals reviewed the record-limited ineffective-assistance claims and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to object to testimony that the gun was listed as stolen on LEIN	Testimony was at most marginally relevant and admissible to the prosecution’s theory	Counsel erred by not objecting to irrelevant and prejudicial testimony	Counsel should have objected, but omission was not prejudicial given the overwhelming evidence of guilt; no new trial
Failure to seek stipulation about prior felonies (avoid stating nature of convictions)	Prior convictions were relevant to an element of felon-in-possession; Mills and related law justify admission	Counsel should have sought a stipulation (Old Chief) to avoid revealing prejudicial conviction details	Counsel’s failure fell below objective reasonableness, but no prejudice shown; verdict stands
Failure to rehabilitate family witnesses who denied seeing a gun/hearing shots	Cross-examination by prosecution impeached family witnesses; rehabilitation might be appropriate	Counsel could have asked about willingness to lie, but tactically chose not to; not ineffective	No ineffective assistance—decision was reasonable trial strategy and any rehabilitation would have had negligible effect
Cumulative effect of counsel’s errors	Combined errors deprived Huffman of a fair trial	Errors together warranted a new trial	Errors (LEIN testimony and failure to seek stipulation) were deficient but cumulatively did not undermine confidence in verdict; affirmed

Old Chief v. United States, 519 U.S. 172 (U.S. 1997) (trial court should accept stipulation to prior conviction to avoid unfair prejudice when the prior’s nature risks improper considerations)
People v. Putman, 309 Mich. App. 240 (Mich. Ct. App. 2015) (standard for proving ineffective assistance of counsel)
People v. Carll, 322 Mich. App. 690 (Mich. Ct. App. 2018) (prejudice inquiry for ineffective assistance: result would have been different)
People v. Sabin, 242 Mich. App. 656 (Mich. Ct. App. 2000) (preservation: move for new trial or Ginther hearing to fully litigate ineffective-assistance claims)
People v. Mills, 450 Mich. 61 (Mich. 1995) (admission of prior convictions and related limits)
People v. Dobek, 274 Mich. App. 58 (Mich. Ct. App. 2007) (test for cumulative error requiring undermining confidence in verdict)
People v. Knapp, 244 Mich. App. 361 (Mich. Ct. App. 2001) (cumulative errors must be seriously prejudicial to warrant reversal)
People v. Ginther, 390 Mich. 436 (Mich. 1973) (right to evidentiary hearing on ineffective-assistance claims)