People of Michigan v. Robert Terrail Williams
333904
| Mich. Ct. App. | Nov 21, 2017Background
- Nov. 21, 2015: bank robbery at PNC in Battle Creek; robber (male) took cash from three tellers, fled in a car with two others, and shots were fired at pursuing police.
- Defendants: Robert Terrail Williams (charged with three counts armed robbery, assault with intent to murder (AWIM), and felony-firearm) and Richard Young (charged with three counts of armed robbery). Whitney Hampton (driver) testified for the prosecution as an accomplice.
- Jury convicted Williams on all counts; sentenced as a fourth habitual offender to long prison terms (45–75 years x3 for armed robbery; 60–90 years AWIM; plus felony-firearm). Young convicted of three counts of armed robbery; sentenced 20–40 years.
- Appeals challenged weight/sufficiency of evidence, sentencing proportionality/scoring, double jeopardy, ineffective assistance of counsel, prosecutorial misconduct, and evidentiary rulings.
- Court of Appeals affirmed all convictions and sentences, finding (inter alia) witness testimony and surveillance supported the verdicts, sentencing within guidelines was reasonable, separate armed‑robbery counts were proper (each teller is a separate victim), and counsel’s choices were not objectively deficient on the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight/sufficiency of evidence (Williams) | Prosecution: eyewitness IDs, surveillance, accomplice testimony support convictions | Williams: Hampton was the actual robber; witnesses unreliable | Affirmed — evidence (IDs, video, testimony) did not preponderate against verdicts; AWIM supported by shots fired at officer indicating intent to kill |
| Sentence proportionality (Williams) | State: guidelines scored, court considered factors; sentence within recommended minimum | Williams: sentence disproportionate | Affirmed — trial court considered factors; sentence within guidelines and no scoring error alleged |
| Double jeopardy (Williams) | State: each teller is a separate victim for armed robbery | Williams: single transaction/one robbery should be one count | Affirmed — unit of prosecution for armed robbery is the person assaulted, so three counts proper |
| Ineffective assistance (Williams) | N/A (prosecution) | Failure to request competency hearing; failure to investigate mental health; failure to request accomplice-instruction | Denied — no record evidence of incompetence; accomplice instruction was given; no apparent deficient performance on record |
| Sufficiency/aid-and-abet (Young) | Prosecution: Hampton’s testimony and circumstantial acts show Young aided/encouraged robbery | Young: insufficient evidence tying him to planning or weapons | Affirmed — circumstantial evidence and Hampton’s testimony permitted conviction as aider and abettor |
| OV9 scoring (Young) | State: ten or more victims placed in danger (tellers, officers, motorists) supports 25 points | Young: fewer victims; contest number | Affirmed — court properly found ten-plus victims; issue waived by defense concession at sentencing |
| Ineffective assistance / prosecutorial misconduct (Young) | N/A (prosecution) | Failures to object to joinder; failure to move to admit polygraph; prosecutor misstatements/permitted perjury | Denied — counsel’s joinder decision was strategic; polygraph motion renewal not warranted; prosecutor’s statements were supported by testimony and not shown to be knowingly false |
Key Cases Cited
- People v Carines, 460 Mich 750 (Mich. 1999) (plain-error standard for unpreserved claims)
- People v Lemmon, 456 Mich 625 (Mich. 1998) (new trial for great‑weight-of‑evidence standard)
- People v Lockridge, 498 Mich 358 (Mich. 2015) (reasonableness review of guideline sentences post-Lockridge)
- People v Milbourn, 435 Mich 630 (Mich. 1990) (proportionality and factors for sentencing)
- People v Wakeford, 418 Mich 95 (Mich. 1983) (unit of prosecution for armed robbery focuses on persons assaulted)
- People v Robinson, 475 Mich 1 (Mich. 2006) (elements for aiding and abetting)