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People of Michigan v. William Lyles Jr
153185
| Mich. | Aug 1, 2017
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Background

  • 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)
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Case Details

Case Name: People of Michigan v. William Lyles Jr
Court Name: Michigan Supreme Court
Date Published: Aug 1, 2017
Docket Number: 153185
Court Abbreviation: Mich.