People of Michigan v. Tynathan Ameire Felder
324621
| Mich. Ct. App. | Mar 17, 2016Background
- Defendant Tynathan Felder was convicted by jury of multiple offenses arising from three similar assaults in May–June 2013: eight counts of first‑degree criminal sexual conduct, conspiracy to commit first‑degree CSC, two counts of armed robbery, first‑degree home invasion, and two felony‑firearm counts. Sentences were long concurrent terms plus consecutive firearm terms.
- Victims placed ads on Backpage.com; defendant responded, went to victims’ residences, threatened them with a gun, forced sex, and robbed them. SANE exams and DNA from semen swabs matched defendant. He admitted being with victims but claimed consensual sex.
- Defense challenged numerous alleged discovery/Brady/Youngblood violations (missing or late videos, phone data, reports, fingerprint and property reports, immunity agreements, witness criminal history) and sought dismissal or mistrial and/or an adverse‑inference instruction.
- Defense also raised a Batson claim alleging a peremptory strike removed a prospective juror because of race.
- Trial court denied relief; on appeal the Court of Appeals affirmed, finding disclosure lapses did not cause actual prejudice or undermine confidence in verdict, no bad‑faith loss requiring an adverse inference, and the prosecutor’s juror strike had a race‑neutral explanation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Late/non‑disclosure of recorded witness interviews and supplemental reports | Prosecutor: failures were inadvertent, some items did not exist; any late disclosures were promptly provided and not material | Felder: Brady/MCR 6.201 violations; evidence would impeach witnesses, affect voir dire, and undermine verdict | No reversible error: late/non‑disclosures did not cause actual prejudice or undermine confidence in verdict; trial court’s remedies adequate |
| Failure to preserve/destroy evidence (in‑car video, phone data) — Youngblood claim | Prosecutor: routine loss/automated deletion; no indication of bad faith | Felder: destroyed evidence could have been exculpatory (impeach witnesses) | No Youngblood relief: loss showed negligence/routine deletion, not bad faith; no undermining of verdict confidence |
| Failure to disclose fingerprint report and other inculpatory/identifying reports | Prosecutor: report prepared late due to inadvertent analyst error; promptly disclosed once found | Felder: late notice hampered voir dire and trial strategy | No prejudice: defense stipulated to report admission; other strong identification evidence (DNA, his admissions) rendered lateness harmless |
| Batson challenge to peremptory juror strike | Prosecutor: strike based on juror’s expressed bias against police—race‑neutral | Felder: strike was race‑based exclusion of African‑American juror | Court: prosecutors’ explanation race‑neutral and credible; trial court did not clearly err — Batson fails |
Key Cases Cited
- Weatherford v. Bursey, 429 U.S. 545 (routine limits on discovery in criminal cases)
- Brady v. Maryland, 373 U.S. 83 (prosecutor must disclose materially exculpatory evidence)
- Arizona v. Youngblood, 488 U.S. 51 (bad‑faith standard for lost/destroyed evidence)
- Kyles v. Whitley, 514 U.S. 419 (materiality test for Brady)
- Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory strikes; three‑step test)
- Hernandez v. New York, 500 U.S. 352 (prima facie Batson issue can be moot once race‑neutral reason offered)
- People v. Chenault, 495 Mich. 142 (Brady materiality standard under Michigan law)
- People v. Knight, 473 Mich. 324 (deference to trial court credibility findings in Batson analysis)
- People v. Davie (After Remand), 225 Mich. App. 592 (actual prejudice requirement for discovery violations)
- People v. Banks, 249 Mich. App. 247 (remedy balancing for discovery violations)
- People v. Sawyer, 222 Mich. App. 1 (police not required to seek out exculpatory evidence)
- People v. Dobek, 274 Mich. App. 58 (standards for instructional error review)
- People v. Kanaan, 278 Mich. App. 594 (weight and credibility of witnesses lie with jury)
- People v. Kurylczyk, 443 Mich. 289 (Wade pretrial identification due‑process standard)
- People v. Petrella, 124 Mich. App. 745 (routine destruction of evidence does not show bad faith)