People of Michigan v. Darren Allen Duffiney

CourtMichigan Court of Appeals
DecidedApril 3, 2018
Docket333378
StatusUnpublished

This text of People of Michigan v. Darren Allen Duffiney (People of Michigan v. Darren Allen Duffiney) 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. Darren Allen Duffiney, (Mich. Ct. App. 2018).

Opinion

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED April 3, 2018 Plaintiff-Appellee,

v No. 333378 Oakland Circuit Court DARREN ALLEN DUFFINEY, LC No. 2015-255461-FH

Defendant-Appellant.

Before: CAMERON, P.J., and SERVITTO and GLEICHER, JJ.

GLEICHER, J. (concurring).

Defendant’s brief on appeal ranks ineffective assistance of counsel as the first issue presented. The heading for this issue declares that trial counsel “was disorganized, unable to follow the court’s rulings, inappropriately focused on minutiae, could not properly impeach witnesses, and was entirely unable to provide an effective defense.” It continues, “Furthermore, counsel made egregious errors including . . . .” The heading identifies three examples: counsel’s introduction of evidence that the complainant was afraid of defendant, defendant’s insistence that the jury view the video of defendant’s interrogation despite that it revealed defendant’s prior conviction for criminal sexual conduct, and defendant’s failure to request a jury instruction for criminal sexual conduct in the fourth degree.

The majority limits its analysis to the last three ineffectiveness claims. According to the majority, the first two arguments listed after “including” are unavailing as trial counsel’s choice to delve into the complainant’s fear qualified as trial strategy and the attempted introduction of the video evidence failed, occasioning no prejudice. The majority finds the jury instruction contention unwarranted. These are easy answers to the three subpoints appellate counsel raised in her statement of the issues presented, and I do not disagree with the majority’s resolution of them.

In my view, however, appellate counsel properly framed a much wider issue for this Court’s review—whether defense counsel “was disorganized, unable to follow the court’s rulings, inappropriately focused on minutiae, could not properly impeach witnesses, and was entirely unable to provide an effective defense.” Appellate counsel devoted more than two dozen pages of her brief to recounting trial counsel’s rambling disjointed questions, his utterly ineffective cross-examinations, and his pointless concentration on collateral and largely irrelevant evidence.

-1- Appellate counsel’s concerns about the adequacy of defendant’s representation are not meritless. I reprint here just a couple of the examples of trial counsel’s performance cited in appellate counsel’s brief. In combination with the rest of the transcript, these segments suggest that counsel lacked focus and basic trial skills. 1

The first excerpt displays defense counsel’s efforts to test the complainant’s memory:

Q. Okay. Now, Ms. [J.], there’s a web page of you that I asked you about on December the 1st, 2015, that shows that you had interest in acting and modeling; do you remember those questions?

A. Yes.

Q. Okay.

Ms. Brown: Your Honor, I object to the relevance of that, of what her interests were.

The Court: Overruled at this time.

By Mr. Lewis:

Q. And Ms. [J.], you went - - you testified that you attended Oakland Community College a/k/a OCC, correct?

Q. And you attended that school from what year to what year?
A. Oh, I went off and on for a couple years. I can’t - -
Q. Take your time - -
A. - - remember the exact dates right now.
Q. Pardon me?
A. I can’t remember the exact dates right now.

The Court: Go ahead, counsel, please.

Mr. Lewis: Are you ready, Ms. [J.]?

The Witness: Yes.

1 Counsel refers to the complainant by her last name, which I have shortened to “Ms. J.”

-2- Q. Now, the - - are you available to continue, Ms. [J.]?

A. Yes, I’ve been ready.
Q. Now, does 2012 to 2015 sound just about right for you attending OCC?
A. No.
Q. So since it doesn’t sound right, tell the jury when you attended OCC?
A. I - - I don’t remember the exact dates?
Q. So how it [sic] that you’re able to dispute it was 2012?
A. That’s not the one I was disputing. I was disputing that it was 2015.
Q. Okay. So you are in agreement with me that you attended OCC in 2012?
A. I think it was from 2011, off and on, until 2014, but I’m not sure exactly.

Q. Ms. [J.], I’m going to refer you to page 57 of the thick transcript, to refresh your recollection. And tell me when you read it.

A. Okay.
Q. Now, does that refresh your recollection as to when you attended OCC?
A. Actually, it says right there that I stated - -
Q. Does that refresh your recollection as to when you attended OCC?
A. It - -
Q. That’s a yes or a no, ma’am.

A. Yes, as I stated right here, I don’t remember exactly. I went on and on for . . . a couple years.

Q. Okay. So it does refresh your recollection as when you attended OCC? Now let’s go - -

Ms. Brown: Your Honor - - no, just one moment, if I may make an objection.

Your Honor, this is asked and answered. She - - he asked - -

-3- The Court: Sustained.

The next excerpt continues trial counsel’s seemingly interminable cross-examination of the complaining witness. In this section, counsel questioned the complaining witness about her reaction to the closing arguments during the first trial (which resulted in a mistrial):

Q. Now, Ms. [J.], you say your behavior was far worse than what it was in the courtroom on December the 3rd, correct?

Q. Now, do you remember your behavior being such that you went up under the pew on December 3rd and you were like - - you were convulsing; do you remember that?

A. I wasn’t convulsing; I was having a panic attack.

Q. Oh, you was [sic] having a panic attack. But you do not dispute that you went up under the pew, correct?

A. I was not under - -

Ms. Brown: Your Honor - -

The Witness: -- a pew.

Ms. Brown: And Your Honor, she’s asked and answered.

The Court: I got the answer. Move on. Go ahead.

Q. Ms. [J.] - -
A. I was sitting on the bench thingy right there.
Q. Okay. So - -
A. I did not get on the ground; I did not go underneath it.

Q. Okay. And the woman right there in the red hair, she was here on December 3rd, wasn’t she?

A. No, she wasn’t.
Q. She wasn’t?

-4- Q. Okay. But you had a friend that was here on December 3rd, correct?

A. Yes, I did.
Q. Okay. And that friend was - - was helping you, correct?
Q. Along with the . . . representative from the prosecutor’s office, correct?
Q. Okay. And they helped calm you down, right?

Ms. Brown: Your Honor, objection as to relevance.

Mr. Lewis: Judge, it’s relevant because she said she was in a much - - she was in a worse condition than what she was - -

The Court: Take - - I’ll take the answer, ma’am.

Mr. Lewis: Thank you.

The Court: Just answer - - just answer the question, and move on after that.

The Witness: I was calmed down a little bit, but I was still infuriated and mad and betrayed.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)

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Bluebook (online)
People of Michigan v. Darren Allen Duffiney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-darren-allen-duffiney-michctapp-2018.