People of Michigan v. Quincy Martinez Husband
333432
| Mich. Ct. App. | Dec 14, 2017Background
- Defendant Quincy Martinez Husband was convicted by a jury of AWIGBH, assault by strangulation, felonious assault, and aggravated domestic assault for assaulting his then‑girlfriend, Sierra Lyles, on April 27, 2015.
- Victim testified Husband choked her until she lost consciousness, was beaten (facial fractures, broken jaw and rib), and required hospitalization and surgery.
- Photographs of the victim’s injuries were taken by Detroit Police Detective James Aude a few days after the assault; Crime Scene Officer Lori Nielsen took additional photos several days later.
- Husband was sentenced as a fourth‑offense habitual offender to lengthy prison terms for the convictions; he appealed raising several claims including anonymous jury, great‑weight challenge, and Brady suppression of photographs.
- The Court of Appeals affirmed the convictions and rejected each of Husband’s appellate arguments.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Husband) | Held |
|---|---|---|---|
| Use of juror numbers / "anonymous jury" | Use of numbers did not withhold information; parties had questionnaires and full voir dire | Addressing jurors by numbers violated due process and impeded meaningful voir dire/presumption of innocence | No plain error; questionnaires and full voir dire meant no prejudice (affirmed) |
| Verdict against great weight of evidence | Victim’s testimony, medical records, photos, and defendant’s admission support strangulation conviction | Strangulation finding is implausible given other evidence; verdict against great weight | No plain error; evidence did not preponderate heavily against verdict; credibility for jury to decide (affirmed) |
| Prosecutor suppressed Nielsen photos (Brady) | Even if disclosure delayed, Nielsen photos taken later would not be favorable or material to change outcome | Prosecutor withheld Nielsen photos that would undermine Aude photos and show no neck marks | No Brady violation: defendant failed to show photos were favorable and material or would have changed result (affirmed) |
| Photographs prejudicially used to invoke sympathy | Photographs were properly admitted and relevant to injuries | Aude photos were unduly prejudicial and used to inflame jury | Abandoned on appeal; in any event no basis for reversal given evidentiary support (affirmed) |
Key Cases Cited
- People v. Hanks, 276 Mich. App. 91 (Mich. Ct. App.) (anonymous jury analysis; questionnaires and voir dire can negate anonymous‑jury concerns)
- People v. Williams, 241 Mich. App. 519 (Mich. Ct. App.) (defines anonymous jury concerns and factors)
- People v. Carines, 460 Mich. 750 (Mich.) (plain‑error standard for unpreserved issues)
- People v. Unger, 278 Mich. App. 210 (Mich. Ct. App.) (great‑weight‑of‑evidence standard)
- People v. Lemmon, 456 Mich. 625 (Mich.) (criteria when witness credibility may warrant new trial)
- Brady v. Maryland, 373 U.S. 83 (U.S.) (suppression of favorable material evidence violates due process)
- People v. Chenault, 495 Mich. 142 (Mich.) (elements and materiality standard for Brady claims)
- People v. Cox, 268 Mich. App. 440 (Mich. Ct. App.) (preservation rules for Brady/suppression claims)
- People v. Schumacher, 276 Mich. App. 165 (Mich. Ct. App.) (Brady claim standardized review)
- People v. Matuszak, 263 Mich. App. 42 (Mich. Ct. App.) (issue‑abandonment doctrine on appeal)
- People v. Carter, 462 Mich. 206 (Mich.) (trial counsel’s approval can waive appellate issues)