D People of Michigan v. Natalie Christina Nelson

CourtMichigan Court of Appeals
DecidedAugust 31, 2023
Docket360860
StatusUnpublished

This text of D People of Michigan v. Natalie Christina Nelson (D People of Michigan v. Natalie Christina Nelson) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
D People of Michigan v. Natalie Christina Nelson, (Mich. Ct. App. 2023).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED August 31, 2023 Plaintiff-Appellee,

v No. 360860 Wayne Circuit Court NATALIE CHRISTINA NELSON, LC No. 19-008280-01-FH

Defendant-Appellant.

Before: GADOLA, P.J., and BORRELLO and HOOD, JJ.

HOOD, J. (dissenting.)

I respectfully dissent. I agree with almost all of the majority opinion, including the majority’s conclusion that the trial court committed an obvious evidentiary error. I, however, disagree with the majority’s conclusion that it was harmless error for the trial court to erroneously exclude the victim, Arron Lewis’s, statement, “I will kill you.” I would reverse for two reasons: (1) even under the test for preserved, nonconstitutional errors, this appears to be outcome determinative; and (2) this exclusion borders on a constitutional error implicating defendant Natalie Christina Nelson’s right to present a defense.

I. BACKGROUND

The proposed opinion accurately describes the facts including those relevant to this issue. Critically, prior to the alleged assault, Nelson confronted Lewis about his contact with his cousin, a child molester, who had sex with Lewis’s sister when she was a minor. They began to argue. During the argument, Nelson grabbed at his neck, scratched him, attempted to hit him, and threw an ashtray at him. These facts are not largely disputed.

Nelson and Lewis provided different accounts of what happened next. Lewis denied choking Nelson before Nelson grabbed her gun, but both Nelson and her son testified that Lewis choked her and that he demonstrated what he had done to her stating, “I just did this to her,” and gesturing. The son also testified that they had physical fights in the past where Lewis choked Nelson. According to trial testimony, Lewis is six feet tall and 175 pounds. Nelson’s height and weight are not part of the record, but according to her testimony, she is short enough that the bed

-1- in the room where this incident happened comes up to her stomach. In short, and as the defense emphasized in closing, Lewis is substantially bigger than Nelson.

According to Nelson, Lewis jumped on top of her and started to choke her to the point that she could not breath. During her direct examination, defense counsel tried to capture the sequence of this conduct in relation to Lewis’s statement to Nelson, “I will kill you,” but the trial court prevented counsel from doing so. The evidentiary error described in the majority opinion occurred in the middle of the sequence of questions about Lewis choking Nelson.

The trial court’s ruling precluded the defense from admitting evidence that Lewis said, “I will kill you,” before he choked Nelson, and before Nelson puller her gun. The trial court never corrected this error.

As the majority observes, the statement came out during Nelson’s cross-examination, but it did not come out in response to a question. The previously excluded statement came out in a non-responsive answer to the prosecutor’s question:

Q. So when you came in the house you immediately asked to see Mr. Lewis’s telephone?

A. No. I seen his name in the phone. And I asked him. I said, “Did Jay call you?” And that’s when he jumped on top of me and started to choke me. And he was saying, “Don’t ever ask me about my f*cking cousin ever again. I will kill you.”

Q. I’m glad you shared all of that. But my question is you came in the house and saw the phone. Is that what you are telling us, you saw the phone?

What followed was a back-and-forth between the prosecution and defense about whether the answer was responsive. It is unclear whether the prosecution purposefully did not move to strike, so as not to emphasize Nelson’s testimony, and shrewdly deflected to other issues with her answer. But because that part of her answer was nonresponsive, the prosecution likely did not open the door for the defense to explore the statement on redirect. The defense did not move for the court to reconsider. And it did not argue that the prosecution opened the door.

This is significant because the statement was potentially part of the body of evidence that the jury could consider, but it only came out in a nonresponsive answer that was the subject of a previously upheld objection. This is different, and likely less credible, than naturally and measuredly providing that statement in response to defense counsel’s nonleading, but very precise and sequential questions.

It also means that the defense could not argue about the statement in closing, because the error was never corrected. Here, where the defense theory was self-defense, the trial court prevented the defense from introducing evidence that the victim said, “I will kill you,” during or immediately before choking the defendant, and prevented the defense from arguing about it in closing argument. Neither the defense, nor the prosecution, referenced the statement during closing.

-2- I otherwise agree with the majority’s summary of the factual background.

II. LAW AND ANALYSIS

Regarding the trial court’s erroneous decision to exclude this statement as hearsay, I agree that this was an error and that the error was preserved. The question is whether it was harmless. It was not.

A preserved error related to the exclusion of evidence “does not warrant reversal unless after an examination of the entire cause, it shall affirmatively appear that it is more probable than not that the error was outcome determinative.” People v Burns, 494 Mich 104, 110; 832 NW2d 738 (2013) (addressing preserved errors for the improper admission of hearsay) (quotation marks, footnote, and citation omitted). “[T]he appropriate inquiry focuses on the nature of the error and assesses its effect in light of the weight and strength of the untainted evidence.” People v Lukity, 460 Mich 484, 495; 596 NW2d 607 (1999) (quotation marks and citation omitted). The burden is on the defendant to prove the error “resulted in a miscarriage of justice . . . .” Id.

Here, Nelson attempted to introduce evidence that the much larger victim got on top of her, choked her, and said “I will kill you,” before she pulled out her gun. The trial court prevented the defense from introducing this, and based on its ruling, prevented the defense from arguing about it in closing. It only came into the body of evidence through Nelson’s self-serving nonresponsive answer to the prosecution’s question on cross-examination. The trial court’s ruling defanged the defense. It took away defense counsel’s ability to use the hallmark trial tactics of primacy and recency to its advantage. To the extent that the evidence came in anyway, it was in a nonresponsive answer that was largely buried by objections and questions about other matters. This necessarily affects the weight and strength of the evidence supporting the self-defense theory. This makes it more likely than not that the error was outcome determinative.

I disagree with the majority’s reliance on People v Unger, 278 Mich App 210, 235; 749 NW2d 272 (2008), to conclude that once the statement came in through Nelson’s nonresponsive answer on cross examination, it was in the body of evidence, and the jury could consider it. In Unger, this Court held juries are presumed to follow the court’s instructions. Id. There, the defendant argued that the court should reverse his conviction because, during closing argument, the prosecutor denigrated defense counsel’s integrity, accused the defense expert of lying, and argued facts not in evidence. Id. at 234.

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Related

People v. Unger
749 N.W.2d 272 (Michigan Court of Appeals, 2008)
People v. Lukity
596 N.W.2d 607 (Michigan Supreme Court, 1999)
People v. Kelly
588 N.W.2d 480 (Michigan Court of Appeals, 1998)
People v. Arenda
330 N.W.2d 814 (Michigan Supreme Court, 1982)
People v. Hayes
364 N.W.2d 635 (Michigan Supreme Court, 1985)
People v. Burns
832 N.W.2d 738 (Michigan Supreme Court, 2013)

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D People of Michigan v. Natalie Christina Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/d-people-of-michigan-v-natalie-christina-nelson-michctapp-2023.