People of Michigan v. Travis Louis Grimes, 327489

On Sept. 9, 2014 Travis Grimes shot and killed Marquis Crooks following a confrontation involving Grimes, Crooks, and Starleshay Ballard (Grimes’s girlfriend); Grimes was convicted by a jury of first-degree premeditated murder and felony-firearm (2nd offense) and sentenced to life without parole plus five years.
Key disputed facts at trial: whether Crooks was armed with a rifle when shot, and who provoked the confrontation. Family/friends of Crooks testified he was unarmed; Grimes and Ballard testified Crooks pointed a rifle at them.
After the prosecutor rested, defense counsel informed the court Ballard’s daughter (an eyewitness) was not present; the court’s comments questioned whether the daughter would be produced that day.
Grimes argues on appeal (1) the court’s remarks effectively prevented presentation of Ballard’s daughter and violated his constitutional right to present a defense, and (2) trial counsel was ineffective for resting rather than seeking a continuance to produce her.
The Court of Appeals reviewed the claims under plain-error (unpreserved) and ineffective-assistance standards and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court’s comments denied defendant his right to present a defense by effectively excluding Ballard’s daughter	The court points to no error — defense never requested an adjournment or ruling; other witnesses testified to the same defense theory	Grimes: court’s statements signaled he could not call the absent daughter, denying his right to present a complete defense	No reversible error; no ruling was entered and defendant made no motion for adjournment; other testimony supported the defense, so no constitutional violation
Whether trial counsel was ineffective for resting instead of seeking a continuance to call Ballard’s daughter	Prosecutor (appellee): counsel’s decisions consistent with trial strategy; defendant failed to show diligence or prejudice	Grimes: counsel performed deficiently by not requesting a continuance to secure the daughter’s testimony, prejudicing the defense	No ineffective assistance: counsel’s choices were plausibly strategic, defendant failed to show diligence to obtain the witness or a reasonable probability of a different outcome

People v Carines, 460 Mich 750 (plain-error standard for unpreserved claims)
Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
People v Buie, 491 Mich 294 (no ruling by trial court means appellate court has nothing to review)
People v Coy, 258 Mich App 1 (standards for adjournment/continuance and factors for good cause)
People v Mesik, 285 Mich App 535 (defendant’s right to present a defense can be satisfied where other testimony supports the defense)