People of Michigan v. Monshaun Daeondrael Norwood
366441
Mich. Ct. App.Apr 14, 2025Background
- Defendant Monshaun Norwood was convicted of capturing/distributing images of an unclothed person, using a computer to commit a crime, and eavesdropping by installing a device.
- Police identified Norwood while investigating pornographic photos left at apartments, secured a confession and phone passcode after advising him of his rights.
- Norwood, who reported being high on marijuana during his initial interview, signed Miranda waivers and consented to a phone search; police later obtained a search warrant for further examination.
- At trial, Norwood’s defense focused on lack of direct evidence and challenged whether a phone constituted a computer under the law.
- Norwood filed for a new trial, alleging ineffective assistance of counsel on several grounds, including failure to suppress statements and inadequate mitigation at sentencing; the trial court denied the motion.
- On appeal, Norwood argued his rights were violated through deficient performance by trial counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel | Defense counsel's strategy was reasonable | Counsel failed to present a legally valid defense | Defense counsel provided reasonable representation |
| Suppression of statements/consent | Statements and consent were valid/voluntary | Statements and consent were involuntary due to intoxication | Waivers and consent were voluntary and valid |
| Motion to suppress phone evidence | Proper procedure followed; consent and then warrant | Evidence from phone should be suppressed as consent coerced | Motion to suppress would have been futile |
| Mitigating evidence at sentencing | Adequate mitigation was considered | Counsel failed to provide sufficient mitigating evidence | No prejudice; no different sentence likely |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (sets standard for ineffective assistance of counsel claims)
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes requirement for advisement of rights during custodial interrogation)
- People v. Walker, 374 Mich. 331 (1965) (procedures for determining voluntariness of confessions)
- People v. Cipriano, 431 Mich. 315 (1988) (factors for determining voluntariness of statements)
- People v. Steanhouse, 500 Mich. 453 (2017) (sentencing must be proportionate to offense and offender)