People of Michigan v. Corey O'Neil Watson

CourtMichigan Court of Appeals
DecidedMarch 9, 2026
Docket369988
StatusUnpublished

This text of People of Michigan v. Corey O'Neil Watson (People of Michigan v. Corey O'Neil Watson) 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. Corey O'Neil Watson, (Mich. Ct. App. 2026).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED March 09, 2026 Plaintiff-Appellee, 11:18 AM

v No. 369988 Wayne Circuit Court COREY O’NEIL WATSON, LC No. 11-002920-01-FC

Defendant-Appellant.

Before: WALLACE, P.J., and GARRETT and ACKERMAN, JJ.

PER CURIAM.

In 2011, a jury convicted defendant of first-degree premeditated murder, MCL 750.316(1)(a), two counts of assault with intent to murder (AWIM), MCL 750.83, intentional discharge of a firearm at an occupied structure, MCL 750.234b, and carrying a firearm during the commission of a felony (felony-firearm), MCL 750.227b. This Court subsequently affirmed his convictions and sentences.1 He thereafter moved for relief from judgment, asserting various errors at trial. The trial court denied his motion, and defendant now appeals. We affirm.

I. BACKGROUND

This case arises out of violence between two rival Detroit gangs: the “KMB” gang, short for “Killers Mean Business,” and the “220” gang, short for “Second to None.” Defendant and his codefendant, Cornelius Robinson, were members of KMB.

On July 24, 2010, a KMB member known as “Tookie” hosted a party on Pelkey Street in Detroit. Members of both KMB and 220 attended the party, though defendant did not. Sometime after midnight on July 25, 2010, a fight broke out on the front lawn between members of the two gangs. Witnesses heard Robinson yell to “get the chopper,” apparently referring to an AK-47 assault rifle, and another gang member then opened fire on the crowd with an AK-47. Robinson

1 People v Watson, unpublished per curiam opinion of the Court of Appeals, issued February 10, 2015 (Docket No. 306989).

-1- was shot in the melee. The partygoers then dispersed, with KMB members leaving the party and 220 members relocating to a nearby residence on Fairport Street.

Later that evening, Reese Williams was driving near the Fairport residence with two members of the 220 gang, Jashawa Nevitt and Devontae Smith, when they heard gunshots coming from the direction of the Fairport house. As Williams drove toward the residence, he was struck in the left upper chest by gunfire from an AK-47. He later died from his injuries.

At trial, Nevitt testified that, moments before the shooting, he saw defendant standing on the sidewalk holding an AK-47. Smith identified defendant as the person he saw running away from the scene immediately after the shooting. Another witness, Aaron Knighten, testified that he was at the Fairport residence when gunshots sounding like AK-47 fire started coming in his direction, causing him and others to run away, only to encounter defendant, who started shooting at them with a handgun from the other direction, which Knighten likened to an ambush. Two other witnesses, La’Trisha Ward and Danique Dumas, testified that they were together in a car near the Fairport house when they heard gunfire. After learning by telephone that Williams had been shot, they were driving to the hospital when they saw defendant running toward a vehicle near Alcoy Street and Seven Mile Road, approximately two blocks from Fairport Street. They did not see anything in defendant’s hands at that time.

The prosecution’s theory was that defendant sought to retaliate against members of 220 for the gunshot Robinson sustained earlier in the evening. It argued that the jury could find defendant guilty of first-degree murder because he shot Williams with the AK-47 or because he aided and abetted the shooter, as the evidence showed he was one of the gunmen involved in the attack.

The jury convicted defendant as described above. The trial court sentenced him to 36 to 60 years’ imprisonment for first-degree murder, 18 years and 9 months’ to 40 years’ imprisonment for each AWIM conviction, 2 years’ imprisonment for felony-firearm, and 2 years’ probation for discharging a firearm at an occupied dwelling. Defendant appealed as of right, challenging a supplemental jury instruction given in response to a juror’s question during deliberations, and this Court affirmed. People v Watson, unpublished per curiam opinion of the Court of Appeals, issued February 10, 2015 (Docket No. 306989), pp 1-3.

In 2023, defendant moved for relief from judgment under MCR 6.500 et seq. He argued that he was denied a fair trial because an erroneous aiding-and-abetting instruction permitted the jury to convict him without finding that he personally possessed the specific intent required for first-degree murder and AWIM. Alternatively, he argued that the evidence was insufficient to support such an instruction. He further alleged that the prosecution presented and failed to correct false or misleading testimony from Smith, Nevitt, and Knighten, and that trial and appellate counsel were ineffective. Defendant asserted that these claims established good cause and actual prejudice under MCR 6.508(D) or that waiver of the good-cause requirement was warranted based on actual innocence. He requested a Ginther2 hearing to develop the record on his ineffective- assistance claims.

2 People v Ginther, 390 Mich 436; 212 NW2d 922 (1973).

-2- The trial court denied the motion in a written opinion and order. It found that defendant failed to establish entitlement to relief under MCR 6.508(D) and that the underlying claims of error lacked merit. Defendant now appeals by leave granted.

II. ANALYSIS

A. STANDARDS OF REVIEW AND GOVERNING LAW

We review for an abuse of discretion a trial court’s decision on a motion for relief from judgment. People v Owens, 338 Mich App 101, 113; 979 NW2d 345 (2021). “The trial court abuses its discretion when it makes an error of law or when its decision falls outside the range of reasonable and principled outcomes.” Id. We review for clear error the trial court’s factual findings supporting its decision on a motion for relief from judgment. People v Poole, 349 Mich App 594, 610; 28 NW3d 769 (2024).

Motions for relief from criminal judgments are governed by MCR 6.500 et seq., which is “the exclusive means to challenge a conviction in Michigan once a defendant has exhausted the normal appellate process.” People v Watroba, 193 Mich App 124, 126; 483 NW2d 441 (1992). A defendant bears the burden of establishing entitlement to relief. MCR 6.508(D).

Because defendant did not raise the claims of error underlying his motion for relief from judgment on direct appeal, he must demonstrate “both good cause for failing to raise such grounds earlier as well as actual prejudice.” People v Johnson, 502 Mich 541, 565; 918 NW2d 676 (2018); see also MCR 6.508(D)(3)(a) and (b). The good-cause prong of MCR 6.508(D)(3) may be “established by proving ineffective assistance of appellate counsel” for failing to raise the underlying claim of error on direct review. People v Reed, 449 Mich 375, 378; 535 NW2d 496 (1995). To establish actual prejudice, a defendant must demonstrate that “but for the alleged error, the defendant would have had a reasonably likely chance of acquittal.” MCR 6.508(D)(3)(b)(i)(A).

Defendant contends that his appellate counsel was ineffective for failing to raise his current claims of error on direct review and that this ineffective assistance constitutes good cause for his failure to raise the claims in his earlier appeal. Because “failing to advance a meritless argument or raise a futile objection does not constitute ineffective assistance of counsel,” People v Baham, 321 Mich App 228, 236; 909 NW2d 836 (2017) (cleaned up), counsel’s failure to raise these claims on direct review constitutes ineffective assistance only if the underlying claims have merit.

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People of Michigan v. Corey O'Neil Watson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-corey-oneil-watson-michctapp-2026.