People of Michigan v. Michael Darnell Sykes
335384
| Mich. Ct. App. | Dec 5, 2017Background
- Defendant Michael Darnell Sykes was convicted by a jury of two counts of kidnapping, five counts of first-degree criminal sexual conduct, and two counts of unarmed robbery arising from attacks on two teenage sisters on August 24, 2008.
- DNA from one victim matched defendant; both victims identified him in a lineup. Prosecutor also introduced April 2009 other-acts evidence of a similar assault/abduction of two other women.
- On the first day of trial the court denied defense counsel Winters' motion to withdraw and refused defendant’s request to remove visible shackles during trial.
- Defendant appealed, challenging admission of other-acts evidence, the shackling decision, denial of counsel’s withdrawal (and alleged constructive denial of counsel), and various suppression/search-warrant issues raised in a supplemental brief.
- The Court of Appeals affirmed: it found the other-acts evidence properly admitted under MRE 404(b) as showing a common scheme/plan; shackling was justified by defendant’s prior courtroom escape attempt; denial of counsel’s withdrawal did not show good cause to substitute counsel nor deprivation of the right to counsel; and suppression/search-warrant/contention of false testimony lacked merit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of other-acts evidence | Evidence of April 2009 assault on CC and DB was admissible to show scheme/plan/identity and not merely character evidence | Admission was unduly prejudicial and improper character evidence under MRE 404(b) | Admitted: similarities (two women, surprise, isolated area, theft and sexual assault) supported inference of common plan; limiting instruction mitigated prejudice |
| Shackling during trial | Shackles were necessary for security given defendant’s prior escape/altercation and to prevent injury/escape | Visible shackling violated due process and prejudiced the jury | No abuse of discretion: prior escape attempt justified restraints; court instructed jurors not to infer guilt from restraints |
| Denial of counsel’s motion to withdraw / substitution | Counsel argued withdrawal based on disagreements; plaintiff (prosecution) implied no good cause for substitution | Defendant argued breakdown in relationship and constructive denial of right to counsel | No abuse: record did not show irreparable breakdown or legitimate dispute warranting substitution; counsel provided meaningful adversarial testing |
| Suppression/search-warrant/false testimony claims (Standard 4 brief) | Evidence from arrest and search was lawful; warrant issued by neutral magistrate; testimony credible | Arrest/search unlawful; warrant based on false statements; conviction based on false testimony | Rejected: issues addressed in companion opinion; defendant offered no basis showing affidavit false or that testimony was untruthful; jury credibility determination stands |
Key Cases Cited
- People v. Bynum, 496 Mich. 610 (2014) (standard for reviewing admission of evidence and abuse of discretion)
- People v. Sabin, 463 Mich. 43 (2000) (similarity test for establishing scheme/plan under MRE 404(b))
- People v. Knox, 469 Mich. 502 (2003) (MRE 404(b) three-part test: proper purpose, relevance, and probative vs. prejudicial balance)
- Deck v. Missouri, 544 U.S. 622 (2005) (due process limits on visible shackling and burdens when error occurs)
- United States v. Cronic, 466 U.S. 648 (1984) (circumstances where right to counsel violation entitles defendant to relief without showing prejudice)