People of Michigan v. Sammy Joseph Hall
332598
| Mich. Ct. App. | Oct 10, 2017Background
- Defendant Sammy Joseph Hall was convicted by a jury of first-degree premeditated murder (MCL 750.316) and felony-firearm (MCL 750.227b) and appealed.
- During trial one juror (Juror 2) violated the court’s admonition against independent research and told other jurors that the murder weapon had been stolen from Georgia.
- The trial court removed Juror 2 after individual questioning of the remaining jurors about whether they had heard the comment and whether it would affect their impartiality.
- Defense counsel expressly agreed on the record not to move for a mistrial, explained his strategy and reliance on the other jurors’ assurances, and asked for a curative jury instruction that juror statements are not evidence.
- The trial court gave the special instruction; defendant later claimed (on appeal) both denial of a fair trial and ineffective assistance of counsel for failing to move for a mistrial.
- The Court of Appeals affirmed, finding the juror-misconduct objection was waived by counsel’s on-the-record agreement and that counsel’s chosen strategy was reasonable and cured by instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether juror misconduct (independent online research by Juror 2) required mistrial | Prosecutor/People: Trial process was proper after removal and questioning; remaining jurors said they could be impartial | Hall: Misconduct infused jurors with inflammatory, prejudicial information requiring mistrial | Court: No reversible error—defense affirmatively waived claim by agreeing to proceed after removal and questioning |
| Whether defense counsel was ineffective for not moving for mistrial | People: Counsel made a strategic, reasonable choice on the record and sought curative instruction | Hall: Counsel’s failure to move for mistrial was objectively unreasonable and prejudicial | Court: No ineffective assistance—counsel’s decision was reasonable trial strategy, and instruction cured any prejudice |
Key Cases Cited
- People v. Carter, 462 Mich. 206; 612 N.W.2d 144 (court reviewed waiver of jury-misconduct claim) (discusses affirmative waiver)
- People v. Jordan, 275 Mich. App. 659; 739 N.W.2d 706 (ineffective-assistance standard: prejudice and deficient performance)
- People v. Rockey, 237 Mich. App. 74; 601 N.W.2d 887 (presumption of effective assistance of counsel)
- People v. Heft, 299 Mich. App. 69; 829 N.W.2d 266 (deference to counsel’s trial strategy)
- People v. Abraham, 256 Mich. App. 265; 662 N.W.2d 836 (special jury instruction can cure juror misconduct)
- People v. Mette, 243 Mich. App. 318; 621 N.W.2d 713 (juries presumed to follow instructions)
- People v. Ginther, 390 Mich. 436; 212 N.W.2d 922 (procedure for evidentiary hearing on ineffective-assistance claims)