People of Michigan v. Steve Treadwell Jr
331310
| Mich. Ct. App. | Jun 27, 2017Background
- Victim Raychel McCoy was shot and killed outside defendant Steve Treadwell Jr.’s home after a heated confrontation on April 29, 2014; defendant and victim had prior animosity involving the victim and defendant’s live‑in girlfriend, Malayshia Melton.
- Earlier that day McCoy allegedly tried to stab Melton; Melton produced a 9mm and later placed it in a downstairs closet at the house where the altercation continued.
- Testimony diverged: Melton said Treadwell took her gun outside, shot McCoy, then returned it to the closet and told her to lie; Melton initially told police she shot McCoy but later pled guilty to a lesser deal and testified for the prosecution.
- A neighbor heard an argument, heard someone ask about getting a gun, then heard multiple gunshots and saw McCoy fall; other witnesses gave inconsistent accounts (one said Melton shot, another said defendant fired into the air).
- At a bench trial the court convicted Treadwell of voluntary manslaughter, felon in possession of a firearm, and felony‑firearm; sentence included 4½–15 years for manslaughter plus consecutive firearm penalties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for voluntary manslaughter | Evidence (Melton’s testimony, neighbor, other witnesses) supports that Treadwell shot McCoy in heat of passion | Melton was the more logical killer; witness credibility undermines verdict | Affirmed — evidence sufficient for conviction |
| Sufficiency of evidence for felony‑firearm | If manslaughter proven and killing committed with a firearm, felony‑firearm elements met | Challenges tied to manslaughter theory (if manslaughter fails, so does firearm count) | Affirmed — felony‑firearm supported by manslaughter finding |
| Validity of jury‑trial waiver | Waiver proceeding on record complied with MCR 6.402(B); defendant personally acknowledged rights and desire to waive | Waiver was not knowing/voluntary; record incomplete and did not explain jury unanimity | Affirmed — colloquy satisfied rule; waiver knowingly and voluntarily made |
| Whether trial court erred in denying withdrawal of jury‑waiver day of trial | Prosecutor and court approved bench trial; court properly exercised discretion | Request to withdraw denied; defendant contends error | Affirmed — court’s acceptance of prior waiver was not clearly erroneous |
Key Cases Cited
- People v Lanzo Constr Co, 272 Mich App 470 (standard for sufficiency review in bench trial)
- People v Kanaan, 278 Mich App 594 (role of trier of fact in weighing credibility)
- People v Ericksen, 288 Mich App 192 (circumstantial evidence and reasonable inferences support conviction)
- People v Pouncey, 437 Mich 382 (definition/distinction of voluntary manslaughter from murder)
- People v Mendoza, 468 Mich 527 (provocation negates malice; elements of voluntary manslaughter)
- People v Johnson, 293 Mich App 79 (elements of felony‑firearm)
- People v Leonard, 224 Mich App 569 (standard for reviewing jury‑waiver validity)
- People v Kurylczyk, 443 Mich 289 (clear‑error standard explained)