People of Michigan v. Robert Leroy Houghtaling
330547
| Mich. Ct. App. | Jun 20, 2017Background
- Defendant Robert Houghtaling was convicted by a jury of second-degree home invasion and safe breaking for a theft from the Bad Axe home of 90‑year‑old Dr. Edward Steinhardt; sentenced as a fourth‑offender to concurrent 11–40 year terms.
- Clark (defendant’s girlfriend) had been hired to care for Steinhardt; defendant had visited the house Feb. 12 to return a steam cleaner and commented about the house being ‘‘rich’’ and having a safe and key in a desk.
- Between the evening of Feb. 13 and morning of Feb. 14 someone forced entry, retrieved the safe key from a desk drawer, opened the safe, and stole over $8,000 and other items.
- The safe key and items bearing defendant/Clark’s names were found in a garbage bag in the dumpster at the apartment complex where defendant and Clark lived.
- Witness testimony placed defendant with a large stack of cash on the evening of Feb. 13, showed substantial Valentine’s Day weekend spending, and established he had $1,110 on his person when arrested a few days later.
- Defendant raised alibi testimony and attacked certain tendered evidence and prosecutor conduct; the trial court admitted contested text messages for impeachment and denied relief on other challenges. Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove identity | Prosecution: circumstantial evidence (motive, opportunity, knowledge of safe and key, sudden cash, discarded key) supports conviction | Houghtaling: alibi and lack of direct evidence; insufficient to prove he committed the break‑in | Affirmed — circumstantial proof and gaps in alibi permitted a rational jury to find guilt beyond a reasonable doubt |
| Admissibility of defendant’s Feb. 14 text messages | Prosecution: texts impeached defendant’s testimony about timing of "flushing" $2,000 and showed timing of excess funds; probative value > prejudice | Houghtaling: texts were highly prejudicial and implicated drugs, not relevant to charged offenses | Affirmed — trial court did not abuse discretion; texts were probative impeachment evidence and not unduly prejudicial |
| Scoring of Offense Variable 19 at sentencing | Prosecution: guideline scoring uncontested at sentencing | Houghtaling: challenges OV 19 scoring on appeal | Waived — defendant and counsel expressly approved scoring at sentencing; issue not preserved |
| Prosecutorial misconduct and other trial errors (Standard 4 brief) | Prosecution: testimony about parole status and financial evidence was relevant to identity/motive; comments and evidentiary rulings were proper or harmless | Houghtaling: prosecutor elicited/failed to control witnesses’ mention of parole/prior record, improperly admitted duplicates of letters, misstated evidence, shifted burden, and committed other misconduct | Reviewed for plain error where not preserved; no prejudice found and no reversal warranted; ineffective‑assistance claims largely unsubstantiated |
Key Cases Cited
- People v Reese, 491 Mich 127 (supports sufficiency review standard and appellate deference)
- People v Lukity, 460 Mich 484 (trial court evidentiary‑admission abuse‑of‑discretion standard)
- People v Wolfe, 440 Mich 508 (deference to jury credibility assessments)
- People v Mills, 450 Mich 61 (MRE 403 unfair‑prejudice balancing)
- People v Carter, 462 Mich 206 (waiver by counsel approval of sentencing/guideline scoring)
- People v Dobek, 274 Mich App 58 (prosecutorial misconduct standard and context analysis)
- Strickland v. Washington, 466 US 668 (ineffective assistance of counsel standard)