People of Michigan v. Miguel Cornell Robinson
330940
| Mich. Ct. App. | May 18, 2017Background
- Victim was robbed at gunpoint while riding his bike; approximately $8 taken. The assailants were in a white SUV; victim saw the robber in the rear driver‑side seat and a masked front passenger.
- Police located and stopped a vehicle the next day; a mask was found in the vehicle. Defendant was placed in a live lineup the day after the robbery.
- The victim immediately identified defendant in the live lineup and later made the same in‑court identification at a bench trial.
- Defendant moved to suppress the lineup and in‑court identification, arguing the officer conducting the lineup told the victim he had picked the right person, rendering the procedure unduly suggestive; the trial court denied the motion.
- Defendant was convicted at a bench trial of armed robbery and later appealed, arguing (1) due‑process violation from an unduly suggestive identification and (2) ineffective assistance of counsel for failing to seek a mistrial on that basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pretrial lineup and in‑court identification admissibility (due process) | Identification reliable under totality of circumstances; not unduly suggestive | Officer’s comment (alleged) made lineup unduly suggestive, tainting in‑court ID | Denied. Lineup not unduly suggestive; immediate ID, proximity in time, details recalled, and victim certainty supported reliability. |
| Ineffective assistance of counsel for not moving for mistrial | Counsel filed a suppression motion and preserved the argument; no deficient performance on meritless claim | Counsel should have moved for a mistrial based on the suggestive ID | Denied. Counsel not ineffective because suppression claim lacked merit and counsel pursued available relief. |
Key Cases Cited
- People v Kurylczyk, 443 Mich. 289 (Mich. 1993) (due‑process test and factors for assessing suggestive identifications)
- People v King, 384 Mich. 310 (Mich. 1970) (post‑identification confirmation by police does not necessarily render an identification unduly suggestive)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part standard for ineffective assistance of counsel)
- People v Johnson, 315 Mich. App. 163 (Mich. Ct. App. 2016) (presumption of effective assistance and standards of review)