People of Michigan v. Raymond Russell Seigneurie
332270
| Mich. Ct. App. | Sep 7, 2017Background
- Defendant Raymond Seigneurie was convicted by a jury of three counts of first-degree criminal sexual conduct (victim under 13). Sentenced to concurrent terms of 20–30 years each.
- The victim (defendant’s eldest daughter) testified to repeated digital penetration from ages ~3–10; she reported the abuse years later after giving birth.
- Other witnesses (victim’s mother, first husband) corroborated parts of the victim’s account and testified about a post-disclosure admission by defendant.
- During trial, the prosecutor introduced two "other acts" (post-move incidents: touching under a nightshirt when victim ~11–12, and touching breasts in a car when victim a teenager) under MCL 768.27a.
- Defendant raised multiple appellate challenges: great-weight-of-evidence, ineffective assistance (failure to object to jury instructions/verdict form and to other-acts admission), admissibility of other-acts given statute of limitations, ex post facto challenge to MCL 768.27a, and PSIR redaction (which trial court already granted).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether convictions were against the great weight of the evidence | Evidence (victim + corroborating witnesses) supported verdicts | Victim’s testimony was impeached, inconsistent, and some allegations defied physical realities | No; verdicts not against great weight; credibility/resolution for jury; corroboration supported verdicts |
| Whether defense counsel was ineffective for failing to object to jury instructions/verdict form | Jury instructions matched Model Crim JI; verdict form issue explained by judge; objections would be futile | Counsel should have objected because instructions/verdict form confused jurors and prejudiced defendant | No; instructions were correct and counsel not ineffective for failing to make futile objections |
| Whether "other acts" evidence (admitted under MCL 768.27a) was inadmissible due to statute of limitations; and related ineffective-assistance claim | Other-acts were "listed offenses" under MCL 28.722 and admissible; statute of limitations does not bar admission; MRE 403 balancing performed | Other-acts were time-barred from prosecution so inadmissible under MCL 768.27a; counsel ineffective for not objecting | No; statute of limitations does not render other-acts unlisted; evidence admissible under MCL 768.27a and MRE 403; counsel not ineffective for failing to raise meritless objection |
| Whether MCL 768.27a violates Ex Post Facto Clauses as applied | Propensity evidence admission retroactively changed law and prejudiced defendant | MCL 768.27a does not reduce quantum of proof; victim testimony alone suffices; statute not ex post facto | No; not an ex post facto violation—admission of propensity evidence does not lower proof required; prior precedent controls |
Key Cases Cited
- People v Lopez, 305 Mich. App. 686 (court reviewed great-weight challenges and preservation) (discusses preservation/plain-error review)
- People v Unger, 278 Mich. App. 210 (discusses new-trial standard for verdict against great weight)
- People v Lemmon, 456 Mich. 625 (discusses deference to jury on credibility unless testimony impeached to no probative value)
- People v Watkins, 491 Mich. 450 (explains MCL 768.27a scope and MRE 403 balancing for other-acts evidence)
- People v Masroor, 313 Mich. App. 358 (illustrates MRE 403 considerations and need to evaluate each other-act separately)
- People v Pattison, 276 Mich. App. 613 (holds MCL 768.27a does not lower quantum of proof; prior uncharged acts admissible)
- Carines v. (People), 460 Mich. 750 (establishes plain-error standard for unpreserved claims)
- Strickland v. Washington, 466 U.S. 668 (establishes two-prong test for ineffective assistance of counsel)