People of Michigan v. Shawn James Jarrett
330460
| Mich. Ct. App. | Feb 16, 2017Background
- Victim Berta Yolanda Reyes disappeared after being dropped off at work at Neal Mast Greenhouses on April 24, 2014; her body was later found near the greenhouse and ruled a homicide.
- Defendant Shawn Jarrett worked at the greenhouse and typically drove a tan car; the victim’s husband saw a tan car in the parking lot the morning she disappeared.
- Defendant left for work around 5:00 a.m., was seen at a nearby gas station just after 5:00 a.m., clocked in at 6:45 a.m., and left work about 8:00 a.m. claiming he was sick.
- Defendant returned home around 12:30 p.m. and immediately cleaned his car; police later found the victim’s blood in the vehicle (headrest) and could not profile another bloodstain.
- The victim’s broken cellphone and case were recovered near the greenhouse; forensic testing matched defendant’s DNA to the phone and case.
- A jury convicted Jarrett of second-degree murder; he was sentenced to 60–90 years as a third-offense habitual offender and appealed on sufficiency-of-evidence grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence to prove Jarrett committed second-degree murder? | The circumstantial evidence (Jarrett’s car at scene/time, his presence nearby, cleaning car, victim’s blood in car, Jarrett’s DNA on victim’s phone) supports conviction. | Evidence is circumstantial and insufficient to link Jarrett to causing the victim’s death beyond a reasonable doubt. | Affirmed — viewing evidence in prosecution’s favor, a rational jury could find Jarrett guilty beyond a reasonable doubt. |
Key Cases Cited
- People v. Lueth, 253 Mich. App. 670 (discussing de novo review of sufficiency challenges)
- People v. Bennett, 290 Mich. App. 465 (standard for viewing evidence in light most favorable to prosecution)
- People v. Cameron, 291 Mich. App. 599 (drawing reasonable inferences and credibility choices to support jury verdict)
- People v. Nowack, 462 Mich. 392 (circumstantial evidence can establish crime elements)
- People v. Goecke, 457 Mich. 442 (elements and definition of malice for second-degree murder)