People of Michigan v. Lemont Santez Ringo
332237
| Mich. Ct. App. | Jun 29, 2017Background
- Defendant Lemont Santez Ringo convicted after a bench trial of second-degree arson for a July 23, 2015 fire at a residence; initially sentenced 72 months–20 years, later resentenced to 51 months–20 years.
- Witnesses Rasheed Biddle and David Jones testified Ringo argued with Biddle that day and threatened to "come back and burn this crib down."
- A neighbor corroborated Ringo’s presence nearby and that she saw the house on fire roughly 20 minutes after Ringo left.
- Detroit Fire Department investigator Jermaine Owens concluded, by process of elimination, the fire was deliberately set and a criminal act; porch and furniture were charred and a picture window was broken.
- Defense emphasized timing and credibility: Biddle testified he saw Ringo drive away and was gone only a few minutes before returning to find the porch burning, arguing Ringo lacked time/opportunity to start the fire.
- The trial court found the testimony and fire investigation supported willful or malicious burning; defendant appealed, asserting the verdict was against the great weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether conviction is against the great weight of the evidence | Evidence (threats, eyewitness testimony, fire investigator’s conclusion) supports arson conviction | Witness timing and credibility undermine conviction; defendant seen leaving and fire shortly after | No — appellate court affirms; evidence does not preponderate against verdict |
| Sufficiency of intent for second-degree arson (willful/malicious) | Threats and deliberate-fire finding show intent or wanton conduct | Defendant lacked opportunity/time to start fire; no direct proof he ignited it | Intent established by threats, opportunity, and investigator’s conclusion; supports conviction |
| Credibility of witnesses | Witnesses consistently testified to threats and events supporting guilt | Conflicting timing estimates and impeachment argue for disbelief | Court defers to fact-finder; credibility issues do not warrant new trial absent depriving testimony of all probative value |
| Preservation of great-weight claim and plain-error review | Not directly addressed by plaintiff; court enforces preservation rules | Claim not preserved by timely new-trial motion, so only plain-error review allowed | Claim not preserved; no plain error affecting substantial rights found |
Key Cases Cited
- People v. Winters, 225 Mich. App. 718 (1997) (timely motion required to preserve great-weight-of-the-evidence claim)
- People v. Cameron, 291 Mich. App. 599 (2011) (appellate review for plain error when great-weight claim not preserved)
- People v. Musser, 259 Mich. App. 215 (2003) (credibility exceptions where testimony deprived of probative value or contradicts indisputable facts)
- People v. Lacalamita, 286 Mich. App. 467 (2009) (definition of verdict being against great weight of evidence)
- People v. McCray, 245 Mich. App. 631 (2001) (standard for weighing evidence relative to miscarriage of justice)
- People v. Nowack, 462 Mich. 392 (2000) (two forms of arson intent: intentional and wanton)
- People v. Barber, 255 Mich. App. 288 (2003) (statute protects buildings and contents; focus on willful burning)
- People v. Simon, 174 Mich. App. 649 (1989) (fire investigation by elimination can support arson conviction)
- People v. Lemmon, 456 Mich. 625 (1998) (credibility determinations reserved for fact-finder)
- People v. Roper, 286 Mich. App. 77 (2009) (conflicting testimony alone does not warrant reversal)