People of Michigan v. Stan Jamario-Deneke Blockton
329608
| Mich. Ct. App. | May 23, 2017Background
- Defendant Stan Blockton was convicted by a jury of assault with intent to commit murder, felon in possession of a firearm, and felony-firearm for the October 3, 2014 shooting of Juarez Gay in a liquor-store parking lot. Sentence: 26–50 years (assault), 5–10 years concurrent (felon-in-possession), plus consecutive 5 years (felony-firearm).
- Surveillance and eyewitness evidence: shooter drove a light-colored Chevrolet Impala with sunroof and spoiler; Gay was shot after a man in such a vehicle pointed a gun and said “Give it up.” Gay later identified defendant in a photographic array.
- Investigation: police followed leads tied to the nickname “Rio,” a vehicle registered to defendant’s wife, and information from officers/informants; defendant was arrested after exiting the stated Impala and a gun was recovered from the trunk; ballistics linked the gun to cartridge cases from the scene.
- Defense raised multiple challenges on appeal: hearsay and Confrontation Clause issues from testimony about the nickname “Rio,” admission of other-act evidence, legality of the vehicle search, prosecutorial failure to correct a witness’s inaccurate ballistics statement, and suggestiveness/validity of the photographic identification.
- Trial court rulings (affirmed on appeal): challenged investigatory statements were admitted for their effect on the investigation (not for truth), MRE 404(b) not triggered, automobile-exception supported the warrantless vehicle search, prosecutor did not knowingly allow false testimony to stand, and photographic array/identification were not impermissibly suggestive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of testimony referencing nickname "Rio" (hearsay/Confrontation Clause) | Testimony explained why officers acted and how suspects were developed | Testimony was inadmissible hearsay and violated Confrontation Clause; counsel ineffective for not objecting | Admitted for non‑hearsay purpose (effect on investigation); no Confrontation violation; no ineffective assistance (objection would be futile) |
| Evidence of an unrelated case/"other acts" (MRE 404(b)) | Testimony about another case was relevant to investigation, identity and chronology | Testimony implicated defendant in other wrongdoing and was unfairly prejudicial | MRE 404(b) not triggered because testimony did not show defendant committed a crime; probative value outweighed any prejudice |
| Legality of warrantless search of defendant’s vehicle (Fourth Amendment) | Search was unlawful (search incident to arrest/Gant) and gun should be excluded | Automobile-exception and probable cause supported search; evidence of drugs on defendant justified search; alternatively inevitable discovery/inventory search | Search lawful under automobile-exception based on probable cause; Gant inapplicable; admission proper (alternative inevitable-discovery noted) |
| Prosecutor’s failure to correct Trooper Girke’s inconsistent ballistics testimony | Prosecutor should have corrected an inaccurate juror‑question response that claimed the bullet matched the gun | Prosecutor later admitted lab report and expert testimony established only cartridge-case match; she did not elicit the inaccurate testimony nor knowingly allow false testimony to stand | No prosecutorial misconduct; lab report and expert testimony corrected record; no plain error |
| Photographic array and in-court identification (due process) | Array was suggestive (background/photo differences) and identification unreliable | Array photos were consistent in format; independent basis existed for identification (prior sightings, observation during crime, prompt and certain ID) | Array not impermissibly suggestive; even if arguendo it were, sufficient independent basis existed for in-court ID; no plain error |
Key Cases Cited
- People v Carines, 460 Mich. 750 (plain‑error standard for unpreserved claims)
- People v Chambers, 277 Mich. App. 1 (informant statements admissible to explain police conduct, not for their truth)
- United States v. Ross, 456 U.S. 798 (automobile exception: probable cause permits warrantless vehicle search)
- Arizona v. Gant, 556 U.S. 332 (limits on searches incident to arrest; distinguished from automobile exception)
- People v. Kurylczyk, 443 Mich. 289 (standards for photographic-array suggestiveness)
- People v. Gray, 457 Mich. 107 (factors to determine independent source for identification)
- People v. Kazmierczak, 461 Mich. 411 (probable cause and search‑warrant exceptions under Michigan law)
- People v. Smith, 498 Mich. 466 (prosecutor’s duty to correct false testimony)