People of Michigan v. Nakia Travis Jones
327631
Mich. Ct. App.Oct 20, 2016Background
- Defendant Nakia Travis Jones was convicted by a jury of delivering less than 50 grams of cocaine (second offense) and sentenced as a fourth-offense habitual offender to 21 months–20 years.
- Grand Rapids police surveilled a gas-station parking lot known for drug activity; Officer Stevens observed Jones approach several people and watched a hand-to-hand exchange between Jones and Terrance Price.
- Price testified he bought a crack rock from Jones for $8; Price was an admitted drug user, had not identified Jones before trial, and testified in exchange for sentencing consideration.
- Officers stopped Jones shortly after the observed exchange and found torn corner of a sandwich bag and $8; they stopped Price nearby and found a crack pipe with a substance testing positive for crack cocaine.
- Jones appealed claiming insufficient evidence/great-weight error, improper admission of officers’ testimony that the area was a high-crime area (and related ineffective assistance), and prosecutorial Brady violation / ineffective assistance for failure to disclose Price’s prior convictions.
- The Court of Appeals affirmed the conviction on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency / great-weight of the evidence | Prosecutor: evidence (Price’s ID, officer observations, drugs found on Price) supports conviction | Jones: only Price’s testimony tied him to the sale; Price had motive to fabricate | Affirmed — viewed in prosecution’s favor, circumstantial and testimonial evidence sufficient; no miscarriage of justice |
| Admission of officers’ testimony that area was high-crime | Prosecution: officers’ lay opinions explained why they were surveilling/responding quickly | Jones: opinion was improper, irrelevant, and unduly prejudicial | Affirmed — lay opinion admissible under MRE 701; probative for context/timing and not unduly prejudicial |
| Ineffective assistance for failing to object to high-crime testimony | N/A | Jones: counsel should have objected; failure was ineffective assistance | Rejected — testimony was admissible; failing to make a futile objection is not ineffective assistance |
| Brady / ineffective assistance for nondisclosure of Price’s priors | N/A | Jones: prosecutor failed to disclose Price’s prior convictions; counsel failed to impeach with them | Rejected — even assuming suppression, priors were not material; failure to impeach not prejudicial to outcome |
Key Cases Cited
- People v Henderson, 306 Mich App 1 (standard for sufficiency review)
- People v Cameron, 291 Mich App 599 (great-weight review)
- People v Kanaan, 278 Mich App 594 (deference to jury credibility findings)
- People v Lemmon, 456 Mich 625 (credibility determinations)
- People v Carines, 460 Mich 750 (plain-error standard)
- People v Murray, 234 Mich App 46 (limits on drug-profile evidence)
- Strickland v Washington, 466 US 668 (ineffective assistance standard)
- Brady v Maryland, 373 US 83 (prosecutor’s duty to disclose favorable, material evidence)
- People v Grant, 470 Mich 477 (investigation and counsel effectiveness)