People of Michigan v. Taurae Monique Canady
333570
| Mich. Ct. App. | Jan 9, 2018Background
- Defendant (Taurae Canady) and her brother Taurus, squatting in their former apartment, planned to use violence to steal money/property to relocate.
- Taurus lay in wait with a sledgehammer; defendant held the door so Taurus could bludgeon maintenance worker Rafael Brown to death on December 17, 2015.
- After the killing, defendant removed Brown’s phone and wallet, took items from his work van (clothing, shoes, radio, change), and assisted in moving the body; they later burned the van.
- The pair were implicated after Taurus posted about the crime; defendant gave stolen property to a teenage stepsister who reported it.
- Procedural posture: defendant was convicted by a jury of first-degree premeditated murder, armed robbery, and fourth-degree arson; she appealed denial of substitute counsel and challenged sufficiency of evidence for armed robbery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by denying substitute counsel | State: court properly required good cause and timely request; denial appropriate given trial imminence | Canady: she repeatedly sought to "fire" appointed counsel and lacked confidence in him | Denial affirmed — no specific breakdown or good cause shown; request made too late and would disrupt trial |
| Whether evidence was sufficient to prove intent to commit larceny (element of armed robbery) | State: planning, statements about needing money, use of a sledgehammer to facilitate theft, and immediate post-mortem taking of property show intent to commit larceny and armed robbery | Canady: Brown was already dead when she stole property, so armed robbery cannot apply | Affirmed — evidence supported that defendant aided/abetted use of a dangerous weapon in an attempt to commit larceny; weapon use to incapacitate (kill) falls within armed robbery statute |
Key Cases Cited
- People v. Traylor, 245 Mich. App. 460 (court reviews substitution decisions for abuse of discretion)
- People v. Mack, 190 Mich. App. 7 (appointment of substitute counsel requires good cause and no unreasonable disruption)
- People v. Buie, 298 Mich. App. 50 (good-cause factors include breakdown of communication or fundamental tactical disagreement)
- People v. McFall, 309 Mich. App. 377 (examples of good cause: tactical disputes, communication breakdown, counsel’s lack of diligence)
- People v. Echavarria, 233 Mich. App. 356 (timely assertion of conflict required; last-minute requests may be denied)
- People v. Gaines, 306 Mich. App. 289 (standard for reviewing sufficiency of the evidence: view evidence in light most favorable to prosecution)
- People v. Solloway, 316 Mich. App. 174 (jury credibility assessments not to be disturbed; circumstantial evidence may suffice)
- People v. March, 499 Mich. 389 (elements required to establish larceny)
