People of Michigan v. Andre Clifford Jacobs

CourtMichigan Court of Appeals
DecidedSeptember 12, 2024
Docket364444
StatusUnpublished

This text of People of Michigan v. Andre Clifford Jacobs (People of Michigan v. Andre Clifford Jacobs) 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
People of Michigan v. Andre Clifford Jacobs, (Mich. Ct. App. 2024).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED September 12, 2024 Plaintiff-Appellee,

v No. 364444 Oakland Circuit Court ANDRE CLIFFORD JACOBS, LC No. 2021-278072-FC

Defendant-Appellant.

Before: K. F. KELLY, P.J., and CAVANAGH and M. J. KELLY, JJ.

PER CURIAM.

Defendant appeals by right his jury-trial convictions of carjacking and stealing a financial transaction device. Defendant was sentenced as a fourth-offense habitual offender to 25 to 50 years’ imprisonment for carjacking and 10 to 15 years’ imprisonment for stealing a financial transaction device, to be served concurrently. Finding no errors warranting reversal, we affirm.

I. BASIC FACTS AND PROCEDURAL HISTORY

This case arises out of the carjacking of the victim and the theft of her credit card in the parking lot of a restaurant on December 18, 2020. After defendant entered the vehicle from the driver’s side, he pushed the victim over and sat on the victim’s legs. Defendant held the victim’s arm as she tried to unlock the passenger door with her other arm. As he lifted himself to get the victim’s purse, the victim pulled her legs out, exited the vehicle on the passenger side, and ran into the restaurant to contact the police.

On December 19, 2020, Officer Michael Stajich observed the victim’s vehicle parked on the northbound side of Coolidge Highway. After Officer Stajich confirmed the vehicle was stolen, he observed it being driven by defendant and followed it, which culminated with defendant jumping out of the moving vehicle and leading officers on a foot chase. Defendant was eventually taken into custody after being found in a garage.

At defendant’s preliminary examination, the victim testified that the man who carjacked her was wearing “a dark colored hoodie,” “a hat underneath the hoodie,” and a mask. The victim saw the man “from the waist up” and “saw his eyes.” The victim stated she saw the carjacker in

-1- the courtroom at the preliminary examination and identified defendant. The victim “watched some of the Zoom [pre]trials” and “definitely recognize[d] [defendant’s] voice 100 percent; never forget that voice.”

After being bound over, defendant moved to suppress the victim’s testimony identifying defendant by voice. Defendant argued the victim’s voice identification was tainted by “the victim’s impermissible actions,” and that admitting the evidence would violate defendant’s due- process rights. Citing People v Murphy (On Remand), 282 Mich App 571, 584; 766 NW2d 303 (2009), the trial court denied defendant’s motion. The trial court noted that under the Crime Victim’s Rights Act, MCL 780.751 et seq., the victim “has a right to be present at any and all hearings as it relates to this case.” The trial court concluded the victim’s identification of defendant’s voice would not be “extremely prejudicial” and found “it [went] to weight more so and not admissibility, and so counsel would have an opportunity to cross-examine the witness about how many times she heard the Defendant’s voice . . . .”

As previously noted, the jury convicted defendant of carjacking, MCL 750.529a, and stealing a financial transaction device, MCL 750.157n, and sentenced defendant as a fourth- offense habitual offender, MCL 769.12, to 25 to 50 years’ imprisonment for carjacking and 10 to 15 years’ imprisonment for stealing a financial transaction device. This appeal followed.

II. STANDARDS OF REVIEW

“This Court reviews for clear error a trial court’s findings of fact made after a suppression hearing, but reviews de novo the ultimate decision on a motion to suppress.” People v Rodriguez, 327 Mich App 573, 583; 935 NW2d 51 (2019). “The trial court’s decision to admit identification evidence will not be reversed unless it is clearly erroneous.” People v Harris, 261 Mich App 44, 51; 680 NW2d 17 (2004). “A finding is clearly erroneous if it leaves this Court with a definite and firm conviction that the trial court made a mistake.” Rodriguez, 327 Mich App at 583 (quotation marks and citation omitted). Issues of constitutional law are reviewed de novo. People v Benton, 294 Mich App 191, 195; 817 NW2d 599 (2011).

II. ANALYSIS

On appeal, defendant argues the victim identified defendant’s voice at the preliminary examination on the basis of impermissibly suggestive procedures, and the trial court erred when it denied defendant’s pretrial motion to suppress this testimony. Defendant also asserts the trial court’s error substantially prejudiced his ability to present a defense, and rendered his trial constitutionally infirm, entitling him to a retrial or evidentiary hearing on the identification. We disagree.

“Identity of the perpetrator is an element in every criminal case.” People v Galloway, 335 Mich App 629, 641; 967 NW2d 908 (2020). “Circumstantial evidence and reasonable inferences arising therefrom may constitute proof of the elements of the crime.” People v Bennett, 290 Mich App 465, 472; 802 NW2d 627 (2010). “[T]his Court has stated that positive identification by witnesses may be sufficient to support a conviction of a crime.” People v Davis, 241 Mich App 697, 700; 617 NW2d 381 (2000).

-2- “Due process protects criminal defendants against the introduction of evidence of, or tainted by, unreliable pretrial identifications obtained through unnecessarily suggestive procedures.” People v Sammons, 505 Mich 31, 41; 949 NW2d 36 (2020) (quotation marks and citation omitted). “Exclusion of evidence of an identification is required when (1) the identification procedure was suggestive, (2) the suggestive nature of the procedure was unnecessary, and (3) the identification was unreliable.” Id. “The fairness of an identification procedure is evaluated in light of the total circumstances to determine whether the procedure was so impermissibly suggestive that it led to a substantial likelihood of misidentification.” Murphy (On Remand), 282 Mich App at 584. “Vocal identification evidence is competent if the identifying witness demonstrates certainty . . . in the mind . . . by testimony that is positive and unequivocal.” Id. (alterations in original). “The credibility of identification testimony is a question for the trier of fact . . . .” Davis, 241 Mich App at 700.

“If a witness is exposed to an impermissibly suggestive pretrial identification procedure, the witness’ in-court identification will not be allowed unless the prosecution shows by clear and convincing evidence that the in-court identification will be based on a sufficiently independent basis to purge the taint of the illegal identification.” People v Colon, 233 Mich App 295, 304; 591 NW2d 692 (1998). “The defendant must show that in light of the totality of the circumstances, the procedure used was so impermissibly suggestive as to have led to a substantial likelihood of misidentification.” Id. “Simply because an identification procedure is suggestive does not mean it is necessarily constitutionally defective.” Id. “The fact that the prior confrontation occurred during the preliminary examination, as opposed to a pretrial lineup or showup, does not necessarily mean that it cannot be considered unduly suggestive.” Id. “If the trial court finds that the pretrial procedure was impermissibly suggestive, testimony concerning that identification is inadmissible at trial.” People v Kurylczyk, 443 Mich 289, 303; 505 NW2d 528 (1993).

“However, in-court identification by the same witness still may be allowed if an independent basis for in-court identification can be established that is untainted by the suggestive pretrial procedure.” Id.

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Related

People v. Colon
591 N.W.2d 692 (Michigan Court of Appeals, 1999)
People v. Gray
577 N.W.2d 92 (Michigan Supreme Court, 1998)
People v. Harris
680 N.W.2d 17 (Michigan Court of Appeals, 2004)
People v. Unger
749 N.W.2d 272 (Michigan Court of Appeals, 2008)
People v. Murphy (On Remand)
766 N.W.2d 303 (Michigan Court of Appeals, 2009)
People v. Kurylczyk
505 N.W.2d 528 (Michigan Supreme Court, 1993)
People v. Davis
617 N.W.2d 381 (Michigan Court of Appeals, 2000)
People v. Konopka (On Remand)
869 N.W.2d 651 (Michigan Court of Appeals, 2015)
People v. Bennett
290 Mich. App. 465 (Michigan Court of Appeals, 2010)
People v. Benton
817 N.W.2d 599 (Michigan Court of Appeals, 2011)

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People of Michigan v. Andre Clifford Jacobs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-andre-clifford-jacobs-michctapp-2024.