People of Michigan v. Raymone Bernard Jackson
327203
| Mich. Ct. App. | Oct 18, 2016Background
- Jackson and Hearn were tried jointly by one jury for multiple violent offenses including first-degree murder; Kamiya Gross died, Chelsea and French injured; revenge plot against French for shooting Hearn; evidence included text messages, rap lyrics, and jail letters; severance petitions denied; confrontation, admissibility of evidence, and instruction issues on involuntary manslaughter appealed; Hearn contends insufficient aiding-and-abetting evidence.
- Defendants plotted revenge against French and his family; Jackson shot French on Holt’s porch, Kamiya killed, Chelsea injured; two defendants presented defenses arguing lack of intent and lack of presence; trial court admitted various evidence; issues raised regarding severance, confrontation, relevance, and jury instructions.
- Court affirmed conviction and held no abuse of discretion on severance or confrontation; rap lyrics evidence admissible; sufficient evidence supported torture conviction; no error in refusal to give involuntary manslaughter instruction; Hearn’s aiding-and-abetting evidence sufficient.
- Judicial economy favors joint trials; severance required only if substantial rights prejudiced; conspiracy-related defenses not antagonistic enough to require severance.
- Evidence admissibility under confrontation clause analyzed with Taylor standard; statements were informal and non-testimonial; no Crawford-type confrontation violation.
- Common-law involuntary manslaughter not warranted; statutory cognate not permissible; no plain error in jury instruction; sufficient evidence for accomplice liability.
- Sufficient evidence supported torture conviction based on intent to cause pain, control over victim, and acts of restraint during shooting, per MCL 750.85.
- Aiding-and-abetting evidence supported Hearn’s liability given close relationship with Jackson, planning through text messages, shared getaway, and coordinated actions; riverwalk footage corroborated flight.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Severance required? | Jackson argues for severance for prejudice | Hearn and Jackson contend joint trial prejudicial | No abuse of discretion; severance not necessary |
| Confrontation violation? | Text messages and letters expose testimonial evidence | Statements informal, non-testimonial | Confrontation Clause not implicated |
| Rape-lyrics evidence admissibility? | Lyrics show intent to retaliate | Unfair prejudice potential | Not an abuse; relevant to motive and plan under proper instruction |
| Sufficiency to convict of torture? | Evidence shows intent and custodial control | Insufficient evidence of custody | Sufficient evidence to support torture conviction |
| Instruction on involuntary manslaughter? | Requested; whether warranted | Not warranted for common-law; statutory cognate excluded | Not error; common-law involuntary manslaughter not warranted; statutory cognate not permissible |
Key Cases Cited
- People v Hana, 447 Mich 325 (1994) (antagonistic defenses must be mutually exclusive for severance)
- People v Bosca, 310 Mich App 1 (2015) (strong policy favoring joint trials; severance reviewed for prejudice)
- People v Etheridge, 196 Mich App 43 (1992) (severance not mandatory absent prejudice to substantial rights)
- Taylor v. United States (cited within Mich. context), 482 Mich 368 (2008) (testimonial versus non-testimonial statements; confrontation clause application)
- People v Mendoza, 468 Mich 527 (2003) (common-law involuntary manslaughter as lesser included offense; standards for instruction)
- People v Carines, 460 Mich 750 (1999) (standard for determining sufficiency of evidence)