People v. Vaughn
291 Mich. App. 183
| Mich. Ct. App. | 2010Background
- June 2002 shooting; Emmitt Smith testified about encounter at his home and pursuit of a car
- Crosby, Huelsenbeck, Staton investigated; car belonged to Vaughn and address near scene
- Defendant Vaughn was at home when police arrived; he admitted being around the corner where his car was involved
- Defendant moved to suppress statements made at his home; issue whether custodial Miranda warnings were required
- Defendant was convicted on two counts of assault with intent to do GBH, felon in possession, and felony-firearm; sentences imposed
- Record later reconstructed on remand; no further relief warranted
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Custodial custody for Miranda purposes at Vaughn's home | State argues noncustodial, noncoercive setting | Miranda warnings required if custodial | Not in custody; no Miranda violation |
| Ineffective assistance—juror challenges | Counsel's strategy during voir dire reasonable | Counsel should have challenged biased jurors | No ineffective assistance; decisions considered trial strategy |
| Ineffective assistance—information quash and alibi witnesses | Evidence supported denial of quash; alibi witnesses lacked evidentiary support | Counsel failed to pursue quash and alibi witnesses | No relief; no prejudice shown |
| Right to a public trial during voir dire | Closure errors presumed prejudicial; remedy required | Closure was permissible with overriding interest | No reversible error; no ineffective assistance shown |
| Missing record and remand restoration on appeal | Record sufficient after remand | Right to appeal impaired by missing portions | No relief; record sufficient to evaluate claims |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (necessity of warnings in custodial interrogations)
- Stansbury v. California, 511 U.S. 318 (U.S. 1994) (custody determination turns on surrounding circumstances)
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (question whether defendant would feel free to leave decides custody)
- Presley v. Georgia, 130 S. Ct. 721 (U.S. 2010) (public trial right includes voir dire closure limits)
- Levine v. United States, 362 U.S. 610 (U.S. 1960) (failure to timely assert public trial right may foreclose relief)
- Hitt v. United States, 473 F.3d 146 (5th Cir. 2006) (failure to object to closure may be strategic; not reversible error)
- United States v. Freytag, 501 U.S. 868 (U.S. 1991) (non-applicable but cited for timely objection principle)