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People of Michigan v. Taurae Monique Canady
333570
| Mich. Ct. App. | Jan 9, 2018
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Background

  • 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)
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Case Details

Case Name: People of Michigan v. Taurae Monique Canady
Court Name: Michigan Court of Appeals
Date Published: Jan 9, 2018
Docket Number: 333570
Court Abbreviation: Mich. Ct. App.