People of Michigan v. Travis Travon Sammons, 332190

Background

Victim Humberto Casas was fatally shot on June 21, 2015; two eyewitnesses (Watkins and Dyjuan Jones) saw a gray/silver Jeep at the scene.
Police stopped a Jeep matching that description ~11 minutes after a dispatch call; defendant Travis Sammons and co-defendant Dominique Ramsey were in the vehicle.
Jones (16 at the time) later viewed defendant singly in a station-house showup and (per MSP Sgt. Rivard) identified him as the shooter; Jones gave contradictory testimony at trial about whether he made that identification at the station.
A composite video tracked a silver Jeep from the shooting location to where it was stopped; Watkins identified a photo of that Jeep as the vehicle she saw.
A jury acquitted Sammons of open murder and weapons charges but convicted him of conspiracy to commit open murder; the trial court granted Ramsey a directed verdict of acquittal on the conspiracy count.
Sammons appealed, challenging (1) denial of suppression of the station-house showup identification, (2) admissibility of Rivard’s testimony recounting Jones’s prior ID, (3) sufficiency/great-weight of the evidence on conspiracy, and (4) alleged prosecutorial misconduct and related ineffective assistance claims.

Issues

Issue	Plaintiff's Argument (People)	Defendant's Argument (Sammons)	Held
1. Admissibility of station-house showup ID	Showup was lawful and reliable; ID admissible under totality of circumstances	Showup was impermissibly suggestive (single-person presentation) and counsel should have used a lineup when suspect was in custody	Denied suppression; showup not so suggestive as to create substantial likelihood of misidentification (totality factors supported reliability)
2. Admissibility of officer testimony recounting prior ID (MRE 801(d)(1)(C))	Rivard’s testimony recounting Jones’s identification is non-hearsay because Jones testified at trial and was cross-examined	Testimony was prejudicial because the showup was improper; thus officer’s recounting should be excluded	Admitted under MRE 801(d)(1)(C); not more prejudicial than probative given showup reliability
3. Sufficiency and great‑weight of evidence for conspiracy	Evidence (witness IDs, vehicle link, video, multiple gunshots) suffices to infer agreement and premeditation	Insufficient identity evidence; one‑man conspiracy rule and inconsistent acquittal of Ramsey require reversal; verdict against great weight of evidence	Conviction affirmed: evidence sufficient for conspiracy; no one‑man conspiracy problem because indictment charged conspiracy with others and evidence supported involvement of other unidentified participants; verdict not against great weight
4. Prosecutorial misconduct and ineffective assistance	Prosecutor’s remarks were proper argument and inference; no misconduct; counsel not ineffective for failing to object	Prosecutor argued facts not in evidence, vouched for officer; counsel should have objected and was ineffective for not doing so	No plain‑error or misconduct found; remarks were permissible argument or based on evidence; failure to object not ineffective (futile)

Key Cases Cited

People v Kurylczyk, 443 Mich. 289 (identification procedures and due‑process suggestiveness standard)
People v Hickman, 470 Mich. 602 (right to counsel attaches at initiation of adversarial proceedings; station showups pre‑charge considered)
People v Malone, 445 Mich. 369 (prior identification admissible as non‑hearsay under MRE 801(d)(1)(C))
People v James Anderson, 418 Mich. 31 (no‑one‑man conspiracy rule and its purpose)
People v Williams, 240 Mich. App. 316 (one‑man conspiracy inapplicable where charging instrument and evidence show conspiracy "with others")
People v Vaughn, 409 Mich. 463 (jury verdicts need not be logically consistent; juries may return seemingly inconsistent verdicts)
People v Lemmon, 456 Mich. 625 (standards for new trial based on great‑weight of the evidence; deference to witness credibility)