People of Michigan v. Steven Leonard Neuman
331400
| Mich. Ct. App. | Jul 25, 2017Background
- Defendant Steven Neuman stabbed and killed Reginald Brown and stabbed Miguel Castaneda during a street confrontation after phone exchanges; Brown was black, defendant and Castaneda white.
- Defendant placed >30 calls to his ex-girlfriend Ceciley Rodriguez; Castaneda answered one call, insults were exchanged, and a meeting for a fight was agreed.
- At the meeting defendant was waiting; Castaneda testified defendant ran up and repeatedly stabbed Brown, then stabbed Castaneda while fleeing; Brown suffered 19 stab wounds.
- Defendant testified there was a mutual fistfight, Brown ‘‘blind‑sided’’ him, and he drew a knife only after being struck, claiming self‑defense and denying intent to kill.
- Jury convicted defendant of first‑degree premeditated murder and assault with intent to murder (AWIM); trial court sentenced him to life without parole for first‑degree murder and a concurrent long term for AWIM.
- On appeal defendant challenged the trial court’s refusal to instruct the jury on (1) voluntary manslaughter as a lesser included of first‑degree murder and (2) assault with intent to do great bodily harm less than murder (AWIGBH) as a lesser included of AWIM; he also raised sufficiency and related claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Whether trial court erred by refusing to instruct voluntary manslaughter as a lesser included of murder | No instruction warranted because insults during earlier phone calls could not be adequate provocation and there was time to cool off | Evidence (defendant’s testimony that Brown blind‑sided him and he only drew the knife after being struck) supported a heat‑of‑passion theory | Court: Error to refuse instruction, but error harmless because jury convicted first‑degree murder and rejected second‑degree, indicating it believed prosecution’s version |
| 2. Whether trial court erred by refusing to instruct AWIGBH as a lesser included of AWIM | Not applicable at trial (prosecutor focused on intent to kill) | Evidence supported only intent to do great bodily harm toward Castaneda; intent to kill was disputed | Court: Error to refuse AWIGBH instruction and error was not harmless; AWIM conviction vacated and remanded for retrial on that count if prosecutor elects |
| 3. Sufficiency of evidence for first‑degree premeditated murder | Evidence (lying in wait, walking to meeting, knife possession, immediate stabbing) shows premeditation and deliberation | Defendant claims mutual fight, no intent to kill, and alternative accounts undermine prosecution theory | Court: Viewing evidence in prosecution’s favor, sufficient evidence supported first‑degree murder conviction; affirmed |
| 4. Prosecutorial misconduct / defendant’s claim that prosecutor injected racism or failed to correct perjury | Prosecutor’s remarks and race‑related evidence were proper and relevant to state of mind; no improper appeal to racial bias | Defendant argues prosecutor injected an element of racism and failed to correct witness falsehoods | Court: No misconduct; references to race and the racial slur were relevant to state of mind and not an improper appeal; perjury/alleged inconsistencies not shown in record |
Key Cases Cited
- People v. Cornell, 466 Mich 335 (instructional‑error harmlessness framework)
- People v. Mendoza, 468 Mich 527 (lesser‑included instruction standard)
- People v. Tierney, 266 Mich App 687 (elements and provocation for voluntary manslaughter)
- People v. Beach, 429 Mich 450 (rejecting intermediate charge shows lack of likelihood jury would adopt lesser charge)
- People v. Bennett, 290 Mich App 465 (elements of first‑degree murder)
- People v. Anderson, 209 Mich App 527 (factors proving premeditation and deliberation)
- People v. Chamblis, 395 Mich App 408 (jury may accept parts of a defendant’s account and reject others)
- People v. Mitchell, 301 Mich App 282 (voluntary manslaughter instruction required where victim struck defendant first)
- People v. Brown, 267 Mich App 141 (AWIGBH is lesser included of AWIM)
- People v. Reese, 491 Mich 127 (imperfect self‑defense and its effect on malice element)