People of Michigan v. Ulises Corrales Vega, 333143

Background

On June 12, 2015 Phineas Oliver was fatally stabbed on a shared porch; defendant Ulises Corrales Vega admitted stabbing Oliver but claimed it was accidental. A 2‑foot samurai sword with Oliver’s DNA on the blade and handle and Vega’s DNA on the handle was recovered from Vega’s apartment. Medical testimony described a ~7‑inch chest stab wound.
Vega was charged with murder and carrying a dangerous weapon with unlawful intent; after a jury trial he was convicted of second‑degree murder and carrying a dangerous weapon with unlawful intent and sentenced to concurrent terms (300–600 months and 23–60 months).
Defense requested jury instructions on voluntary and involuntary manslaughter and on accident; the trial court declined involuntary manslaughter and accident instructions and omitted the second paragraph of M Crim JI 6.2 (intoxication defense paragraph regarding unknowingly becoming intoxicated).
During deliberations the jury requested transcripts of testimony; the court had the court reporter prepare them and provided McConnel’s transcript to the jury when it was ready (before Vega’s transcript was completed) without notifying counsel; the jury returned a verdict before receiving Vega’s transcript.
Vega appealed arguing (1) error for refusing involuntary manslaughter and accident instructions and for partially omitting M Crim JI 6.2, (2) ineffective assistance of counsel for several alleged strategic failures, and (3) denial of the right to counsel by the court’s transcript procedure. The Court of Appeals affirmed.

Issues

Issue	People’s Argument	Vega’s Argument	Held
Whether involuntary manslaughter instruction was required	Evidence showed forceful stabbing with a weapon capable of killing; malice supported.	Vega’s testimony that stabbing was accidental and he only intended to “pinch” Oliver showed gross negligence supporting involuntary manslaughter.	Court: No abuse of discretion; rational view of evidence required malice, so no involuntary manslaughter instruction.
Whether an accident instruction should have been given	Not necessary because evidence showed purposeful stabbing; defense strategy conceded intentional act without requisite specific intent for first‑degree murder.	Failure to give accident instruction deprived Vega of a valid defense.	Waived (not requested) and, in any event, no miscarriage of justice; evidence did not support accident verdict.
Whether omission of second paragraph of M Crim JI 6.2 (intoxication) was error	Only pertinent portions required; no evidence Vega unknowingly became intoxicated so paragraph (2) was inapplicable.	Entire model instruction should have been read; omission prejudiced defense.	Waived (defense satisfied with instructions) and correct on the merits—omitted paragraph was inapplicable.
Whether court’s provision of McConnel transcript alone during deliberations violated right to counsel / required mistrial	Transcript provision was administrative (availability of evidence) not a critical stage; counsel had opportunity to object and move for mistrial; no prejudice shown.	Court acted without counsel input in responding to jury request; ex parte action denied assistance of counsel and requires reversal without prejudice showing.	Communication was administrative; no structural denial of counsel and no demonstrated prejudice; trial court did not abuse discretion in denying mistrial.

Key Cases Cited

People v Gillis, 474 Mich 105 (malice definition and standards for manslaughter instructions)
People v Musser, 494 Mich 337 (abuse of discretion standard for instruction rulings)
People v Mills, 450 Mich 61 (requirement to give requested instructions supported by evidence)
People v Nickens, 470 Mich 622 (lesser‑included instruction standard)
People v Mendoza, 468 Mich 527 (manslaughter as lesser of murder instruction rule)
People v Holtschlag, 471 Mich 1 (distinguishing malice from gross negligence for manslaughter)
People v Kowalski, 489 Mich 488 (waiver where defendant expressed satisfaction with instructions)
People v Heft, 299 Mich App 69 (review limited to mistakes apparent on the record when Ginther remand denied)
People v Carbin, 463 Mich 590 (prejudice standard for ineffective assistance claims)
Cronic v. United States, 466 U.S. 648 (structural error and complete denial of counsel doctrine)
People v France, 436 Mich 138 (categorization of ex parte communications with jury as administrative)
People v Russel, 471 Mich 182 (structural error discussion and right to counsel)