People of Michigan v. Rodney Cornelius Shelton
330803
| Mich. Ct. App. | Mar 9, 2017Background
- Defendant Rodney Cornelius Shelton was convicted by a jury of armed robbery and first-degree home invasion; sentenced as a habitual third offender to concurrent long prison terms.
- Victim Melissa Harrison identified Shelton as her assailant; police later prepared a photographic lineup including Shelton’s photo.
- Shelton moved to suppress Harrison’s photographic identification, arguing the photographic array was unduly suggestive because his head was tilted and his photo differed from the others.
- Shelton also argued Harrison’s independent social-media search and report to police tainted the identification because she told police she had identified him before the array was composed.
- The trial court denied the suppression motion; the Court of Appeals reviewed the denial and affirmed the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the photographic lineup was impermissibly suggestive | The People argued the array was not unduly suggestive and identification was reliable | Shelton argued his photo stood out (head tilt) making misidentification substantially likely | Court held array was not impermissibly suggestive; minimal head-tilt difference went to weight, not admissibility |
| Whether Harrison’s independent social-media search tainted ID | The People argued no improper law-enforcement suggestion occurred | Shelton argued Harrison told police she identified him from Facebook before the array, creating impermissible suggestion | Court held record showed no impermissible suggestion by police; Gray did not apply to taint here |
| Whether an independent basis for in-court ID was required | The People maintained pretrial ID procedures were proper; independent-basis inquiry unnecessary | Shelton urged that, if array was suggestive, the court must find an independent basis for in-court ID | Court found suppression denial not clearly erroneous and did not reach independent-basis issue; noted in-court ID was detailed and unequivocal |
| Standard of review for suppression denial | N/A | N/A | Court applied de novo review to legal issues and clear-error to trial court’s factual finding; no clear error found |
Key Cases Cited
- People v McDade, 301 Mich. App. 343 (discusses standard for impermissibly suggestive photographic identifications and standard of review)
- People v Hornsby, 251 Mich. App. 462 (differences among photos affect weight, not admissibility, unless readily apparent to witness)
- People v Kurylczyk, 443 Mich. 289 (differences in photograph composition do not automatically render lineup impermissibly suggestive)
- People v Gray, 457 Mich. 107 (improper suggestion can occur when witness believes police have the right suspect or is shown a singled-out person)
- People v Barclay, 208 Mich. App. 670 (independent-basis inquiry arises when pretrial ID is tainted)
Affirmed.