People of Michigan v. Hector William Galindez

CourtMichigan Court of Appeals
DecidedJanuary 11, 2024
Docket361654
StatusUnpublished

This text of People of Michigan v. Hector William Galindez (People of Michigan v. Hector William Galindez) 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. Hector William Galindez, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED January 11, 2024 Plaintiff-Appellee,

v No. 361654 Isabella Circuit Court HECTOR WILLIAM GALINDEZ, LC No. 2021-001436-FH

Defendant-Appellant.

Before: BOONSTRA, P.J., and O’BRIEN and SWARTZLE, JJ.

PER CURIAM.

Defendant appeals as of right his jury-trial convictions of two counts of delivering methamphetamine, MCL 333.7401(2)(b)(i) and MCL 333.7212(1)(h), second offense, MCL 333.7413(1); possession of methamphetamine, MCL 333.7403(2)(b)(i) and MCL 333.7212(1)(g); possession of a dangerous weapon, MCL 750.224(1)(d); and two counts of carrying a concealed weapon, MCL 750.227(2). We affirm.

I. BACKGROUND

Defendant’s convictions arise from his delivering methamphetamine to a confidential informant. The informant began working with the Michigan Investigative Narcotics Team after a methamphetamine pipe was discovered in her vehicle. As part of this work, the confidential informant coordinated with the lead detective of defendant’s case to conduct two controlled buys involving defendant. She agreed that, during a previous hearing in defendant’s case, she had testified against defendant when she had a pending criminal charge. Although no one had promised her that her charges would be reduced, she ultimately pleaded guilty to a lesser offense, and her recommended sentence allowed her to attend drug treatment instead of serving jail time.

When testifying about the first controlled buy, the confidential informant told the jury that defendant contacted her and asked her whether she wished to purchase some methamphetamine. After consulting with the lead detective, the informant agreed to set up the purchase. The lead detective testified that, at the prebuy meeting location, he saw a videoconference conversation between the informant and defendant about where to meet. The confidential informant drove to that location and entered a brown vehicle. Although the lead detective testified that he could not

-1- see the occupants of the brown vehicle, a different surveillance officer testified that he recognized the person in the driver’s seat as defendant. The confidential informant testified that she handed defendant money and he handed her methamphetamine.

As to the second controlled buy, the confidential informant testified that defendant again contacted her and offered to sell her methamphetamine, and after consulting with the lead detective, the informant again set up the purchase. The purchase was to take place in a home. The confidential informant was equipped with a video recording device and driven to the home by the lead detective’s partner. Although the informant was the only person who went into the home, the recording showed defendant separating the methamphetamine for the sale. When defendant was eventually arrested, methamphetamine, knives, and a small bat were discovered in his car. The jury found defendant guilty of the previously described offenses.

This appeal followed.

II. PROSECUTORIAL MISCONDUCT

On appeal, defendant challenges several statements made by the prosecutor during trial that, according to defendant, amounted to prosecutorial misconduct. First, defendant challenges the prosecutor’s statements in his opening and closing remarks that the jury should “do the right thing” by convicting defendant, contending that these remarks constituted an impermissible civic- duty argument. Second, defendant challenges the prosecutor’s statements in his closing rebuttal that the informant “testified well,” arguing that such a statement improperly bolstered the informant’s credibility. Reviewing the prosecutor’s statements in context, we conclude that defendant’s arguments lack merit.

Defendant failed to preserve an appellate challenge to the prosecutor’s contested statements by challenging the statements before the trial court, so his claims of prosecutorial misconduct are reviewed for plain error. People v Lane, 308 Mich App 38, 62; 862 NW2d 446 (2014). To establish plain error, the defendant must show that (1) error occurred, (2) the error was clear or obvious, and (3) the error affected defendant’s substantial rights, which generally requires showing that the error affected the outcome of the lower court proceedings. People v Carines, 460 Mich 750, 763; 597 NW2d 130 (1999).

The test for prosecutorial misconduct is whether the defendant was denied a fair and impartial trial. People v Dobek, 274 Mich App 58, 63; 732 NW2d 546 (2007). Issues of prosecutorial error are analyzed “on a case-by-case basis, reviewing the prosecutor’s comments in context and in light of the defendant’s arguments.” Lane, 308 Mich App at 62-63.

First addressing defendant’s civic-duty argument, while prosecutors are generally “given great latitude regarding their arguments,” People v Mullins, 322 Mich App 151, 172; 911 NW2d 201 (2017), they nevertheless “should not resort to civic duty arguments that appeal to the fears and prejudices of jury members,” People v Bahoda, 448 Mich 261, 282; 531 NW2d 659 (1995). Such arguments are generally improper because they “inject issues into a trial that are broader than the defendant’s guilt or innocence,” inviting jurors to suspend their judgment and decide the case not on the facts but on extraneous considerations. Lane, 308 Mich App at 66. Despite this limitation, prosecutors are free to argue the evidence and all reasonable inferences from that

-2- evidence as it relates to their theory of the case, Bahoda, 448 Mich at 282, and are even free to urge the jury to find the defendant guilty on the basis of the evidence and argue that, as a result, justice will be done, Lane, 308 Mich App at 66.

Reviewing the prosecutor’s statements urging jurors to “do the right thing” in context, we conclude that these statements did not amount to improper civic-duty arguments. Throughout the prosecution’s lengthy opening statement, the prosecutor repeatedly urged the jury to focus on the facts and evidence, and said that, if the jury did so, “I’m confident that it will lead you to—or lead us to the right conclusion. And that is, that we have to do the right thing and we’ve got to hold the Defendant Hector Galindez accountable, all right?” The prosecutor made similar statements during his initial closing and rebuttable arguments; after summarizing the counts and the evidence that the prosecutor believed supported each count, he ended by urging the jury to “do the right thing” and hold defendant accountable.1 These statements by the prosecutor did not inject issues broader than defendant’s guilt or innocence into the trial. Nor did the prosecutor ask the jury to suspend its powers of judgment and find defendant guilty on the basis of civic duty; rather, he urged the jury to “do the right thing” by finding defendant guilty on the basis of the facts and evidence that had been presented to it. Accordingly, defendant has not established an error, much less the clear or obvious error that he must show to meet the plain-error standard.

Second, addressing defendant’s argument that the prosecutor impermissibly bolstered the informant’s credibility, “the prosecutor cannot vouch for the credibility of his witnesses to the effect that he has some special knowledge concerning a witness’ truthfulness.” Bahoda, 448 Mich at 276. In a similar vein, the prosecutor may not suggest that he or she has knowledge unknown to the jury that establishes the witness testified truthfully. People v Jackson, 313 Mich App 409,

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Related

People v. Thompson
730 N.W.2d 708 (Michigan Supreme Court, 2007)
People v. Bahoda
531 N.W.2d 659 (Michigan Supreme Court, 1995)
People v. Griffin
597 N.W.2d 176 (Michigan Court of Appeals, 1999)
People v. Carines
597 N.W.2d 130 (Michigan Supreme Court, 1999)
People v. McKenzie
522 N.W.2d 661 (Michigan Court of Appeals, 1994)
People v. Dobek
732 N.W.2d 546 (Michigan Court of Appeals, 2007)
People v. Lane
862 N.W.2d 446 (Michigan Court of Appeals, 2014)
People v. Jackson (On Reconsideration)
884 N.W.2d 297 (Michigan Court of Appeals, 2015)
People of Michigan v. Shae Lynn Mullins
911 N.W.2d 201 (Michigan Court of Appeals, 2017)
People v. Jackson
808 N.W.2d 541 (Michigan Court of Appeals, 2011)
People v. Armstrong
851 N.W.2d 856 (Michigan Court of Appeals, 2014)
People v. Traver
917 N.W.2d 260 (Michigan Supreme Court, 2017)

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People of Michigan v. Hector William Galindez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-hector-william-galindez-michctapp-2024.