People of Michigan v. William Lyles Jr
153185
| Mich. | Aug 1, 2017Background
- In 1983 Andrew “Melvin” Weathers was murdered in a Highland Park home; residents (including ex‑girlfriend Louise Kountz’s teenage daughters) identified a figure they believed to be William Lyles and an arrest warrant issued in 1984; Lyles fled and was arrested in 2012.
- At the 2013 trial the prosecution introduced extensive testimony of Lyles’s prior domestic violence against Kountz (family, neighbors, and others), and identification testimony from Kountz’s daughters linking Lyles to the scene.
- Lyles presented minimal good‑character evidence (reputation/opinion testimony from three witnesses, principally a longtime acquaintance who had limited contact during the relevant period).
- Defense requested M Crim JI 5.8a(1) (instruction that good‑character evidence alone can create reasonable doubt); the trial court refused and instead gave an instruction focused on witness truthfulness and other‑acts evidence.
- The Court of Appeals twice reversed for a new trial, holding the instructional error not harmless; the Michigan Supreme Court granted review to apply the Lukity harmless‑error standard and ultimately reversed the Court of Appeals, reinstating the conviction.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Lyles) | Held |
|---|---|---|---|
| Whether preserved nonconstitutional jury‑instruction error (failure to give M Crim JI 5.8a(1)) is subject to harmless‑error review and, if so, whether the error was harmless under Lukity | Error should be reviewed for harmlessness under MCL 769.26; given the weight of prosecution evidence, any instructional omission was not outcome‑determinative | The omission deprived jurors of an instruction that Lyles’s good‑character evidence alone could create reasonable doubt; that error was outcome‑determinative and required a new trial | Error is subject to Lukity harmless‑error review; under that standard Court finds defendant failed to show it is "more probable than not" the error affected the verdict — instruction omission was harmless and conviction reinstated |
Key Cases Cited
- People v Lukity, 460 Mich. 484 (establishes harmless‑error test: defendant must show it is "more probable than not" the error was outcome‑determinative)
- People v Elston, 462 Mich. 751 (directs focus on nature of the error in light of weight and strength of untainted evidence)
- People v Rodriguez, 463 Mich. 466 (discusses when instructional error can be outcome‑determinative)
- People v Silver, 466 Mich. 386 (addressing instruction significance; cited for support though fractured opinion)
