People of Michigan v. Ronald Earl Williams, 332192

Defendant Ronald Earl Williams, on parole, was required to wear and keep charged an electronic tether; from July 10–19, 2015 the tether was off for 44 hours due to a dead battery.
Charged and convicted at a bench trial of tampering with an electronic monitoring device, MCL 771.3f; sentenced as a fourth-offense habitual offender to 2–10 years.
At trial defendant admitted knowing he had to keep the tether charged and how to charge it, but claimed he charged it daily and was unaware it was not charging properly.
MDOC notified defendant by phone on July 17 and July 19 that the tether battery was low; parole agent’s charge log showed long gaps between charges and recharging only after the battery died.
Defense counsel stipulated that defendant lacked authorization to allow the battery to die but argued a tactic that defendant believed the device was malfunctioning; the court found the parole hearing statements more credible than trial testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was counsel ineffective for stipulating defendant lacked authorization to let the tether die?	Counsel’s stipulation was reasonable and part of trial strategy; evidence showed lack of authorization.	Stipulation conceded an element and amounted to ineffective assistance.	No—strategy reasonable; even if deficient, outcome would not likely differ.
Was there sufficient evidence that defendant knowingly circumvented the tether by letting the battery die?	Charge log, prior knowledge, parole-agent testimony, and defendant’s parole-hearing statements support knowledge.	He charged daily and was unaware of malfunction; credible explanation for gaps.	Yes—viewing evidence in prosecution’s favor, a rational trier of fact could find knowledge beyond a reasonable doubt.

People v LeBlanc, 465 Mich 575 (2002) (standard for ineffective assistance claim)
People v Matuszak, 263 Mich App 42 (2004) (mixed question review; factual findings deferred, legal de novo)
People v Sabin (On Second Remand), 242 Mich App 656 (2000) (review limited to record when no new-trial motion/hearing requested)
People v Rockey, 237 Mich App 74 (1999) (deference to counsel’s tactical decisions)
People v Lane, 308 Mich App 38 (2014) (sufficiency review: view evidence in light most favorable to prosecution)
People v Kanaan, 278 Mich App 594 (2008) (minimal circumstantial evidence can establish intent/knowledge)
People v Mardin, 487 Mich 609 (2010) (trial court credibility determinations afforded deference)