People v. Daniels
311 Mich. App. 257
| Mich. Ct. App. | 2015Background
- Defendant Daniel Daniels was convicted by a jury of multiple counts of first- and second-degree criminal sexual conduct and second-degree child abuse for sexually and physically abusing two daughters (A.D., O.D.); other children also testified about physical and sexual abuse.
- The prosecutor’s charges arose from Care House interviews of A.D. and O.D. in 2012 (and prior interviews in 2010); trial occurred December 2013.
- Over a year before trial defense counsel sought public funds for an expert on forensic interview techniques; the court allocated funds and continued trial multiple times.
- Defendant ultimately proceeded pro se (with advisory counsel). He moved the day before trial to adjourn so a proposed expert (Dr. Okla) could testify; the court denied the adjournment for lack of diligence and prejudice showing.
- The trial court barred defendant from personally cross-examining three child witnesses (A.D., O.D., K.D.) and required his advisory counsel to ask questions he drafted — the court found personal questioning would retraumatize/harass the children.
- The court admitted other-acts testimony from other children under MCL 768.27b/a to show defendant’s history of domestic violence and abuse; defendant appealed on grounds of denial of defense/self-representation and improper other-acts evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of adjournment to secure forensic-interview expert | State: defendant failed to show diligence or good cause; trial court had accommodated delays | Daniels: denial deprived him of right to present a defense (expert testimony) | Denial affirmed; defendant was negligent, not diligent, and showed no prejudice from absence of expert |
| Restriction on personal cross-examination of child witnesses | State: court may limit self-representation to prevent harassment under MRE 611(a) and protect children | Daniels: prohibition violated his right to represent himself and confront witnesses | Restriction upheld; defendant could control questioning via counsel and children would have been traumatized |
| Admission of other-acts evidence (physical abuse of other children) under MCL 768.27b | State: evidence is relevant to show pattern/history of domestic violence and is admissible unless MRE 403 outweighs probative value | Daniels: challenged trial court’s admission as prejudicial | Admission affirmed; testimony was relevant, fit MCL 768.27b, and probative value not substantially outweighed by unfair prejudice |
| Whether limitations implicated Maryland v. Craig protections | State: Craig addresses confrontation when witness testifies outside courtroom; not triggered here | Daniels: invoked Craig/ confrontation concerns | Court rejected Craig claim as inapplicable; defendant still confronted witnesses through counsel |
Key Cases Cited
- People v Trakhtenberg, 493 Mich 38 (de novo review of constitutional questions)
- People v Coy, 258 Mich App 1 (adjournment denial requires showing of prejudice; good cause/diligence required)
- People v Yost, 278 Mich App 341 (right to present a defense not absolute; must follow rules of procedure)
- People v Blackston, 481 Mich 451 (MRE 403 balancing factors)
- People v Crawford, 458 Mich 376 (relevance standard for evidence)
- People v Cameron, 291 Mich App 599 (MCL 768.27b permits admission of other domestic-violence acts)
- Fields v Murray, 49 F.3d 1024 (4th Cir.) (trial court may deny defendant personal cross-examination of child victims to prevent further trauma)
- People v Bynum, 496 Mich 610 (importance of showing relevance and potential benefit of proposed expert testimony)