People of Michigan v. Howard Shane Hector

CourtMichigan Court of Appeals
DecidedDecember 12, 2025
Docket368501
StatusUnpublished

This text of People of Michigan v. Howard Shane Hector (People of Michigan v. Howard Shane Hector) 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. Howard Shane Hector, (Mich. Ct. App. 2025).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED December 12, 2025 Plaintiff-Appellee, 2:06 PM

v No. 368501 Ingham Circuit Court HOWARD SHANE HECTOR, LC No. 19-000052-FH

Defendant-Appellant.

Before: KOROBKIN, P.J., and MURRAY and MALDONADO, JJ.

PER CURIAM.

Defendant appeals by right his jury-trial convictions of operating under the influence (OUIL) causing death, MCL 257.625(4)(a), and reckless driving causing death, MCL 257.626(4). The trial court sentenced defendant to terms of 86 to 180 months’ imprisonment for each of his convictions. Defendant argues that the trial court violated his due process rights by empaneling an anonymous jury and by improperly making a factual determination on an element of the offense. Additionally, defendant argues that the trial court erroneously assessed 15 points for Offense Variable (OV) 5 without record evidence of serious psychological injury to family members, and imposed a disproportionate and unreasonable minimum sentence despite it falling within the applicable guideline range. We affirm.

I. BACKGROUND

This case arises from a fatal road-rage incident that led to a collision between two vehicles, resulting in the death of one of the drivers. Defendant was operating one of the cars involved, and Wade Warner, who was driving the other vehicle, was killed in the crash. The evidence at trial established that shortly before the accident, Warner was driving behind defendant after defendant had blocked Warner from passing him and that defendant had engaged in aggressive behavior by “brake-checking” Warner at least three times. After the accident, Warner was found nearby, suffering catastrophic injuries, which included his left arm being traumatically amputated. Defendant admitted to the police during their subsequent investigation that he was driving between 60 and 65 miles per hour. The posted speed limit was 55 miles per hour. A blood test revealed that defendant had a blood alcohol level of 0.124 %.

-1- II. ANONYMOUS JURY

Defendant first argues that he was denied his right to a fair and impartial jury under the Sixth Amendment and his due process rights under the Fourteenth Amendment when the trial court empaneled a jury identified only by numbers and failed to provide a proper cautionary instruction. We disagree.

A. STANDARD OF REVIEW

To preserve a challenge to the trial court’s decision to refer to jurors by number rather than by name, a defendant must object to that decision in the trial court. People v Hanks, 276 Mich App 91, 92; 740 NW2d 530 (2007). Defendant failed to preserve this issue for appellate review. Although defense counsel remarked on the record that he was having a hard time assimilating assigned juror numbers, counsel did not raise a clear or specific objection to the use of juror numbers, nor did he assert that the empaneling of an anonymous jury violated defendant’s constitutional rights. We review unpreserved issues for plain error, regardless of whether the issue has constitutional implications. People v Thorpe, 504 Mich 230, 252; 934 NW2d 693 (2019). Under plain-error review, “a defendant must prove that (1) error occurred, (2) the error was plain, i.e., clear or obvious, and (3) the plain error affected substantial rights.” People v Davis, 509 Mich 52, 67; 983 NW2d 325 (2022) (quotation marks and citation omitted). “An error has affected a defendant’s substantial rights when there is a showing of prejudice, i.e., that the error affected the outcome of the lower court proceedings.” People v Walker, 504 Mich 267, 276; 934 NW2d 727 (2019) (quotation marks and citation omitted)

B. ANALYSIS

The Fourteenth Amendment to the United States Constitution protects a defendant’s right to due process, including the right to a fair and impartial jury. US Const, Am XIV. There are two primary published cases addressing the issue regarding the use of an anonymous jury: People v Williams, 241 Mich App 519; 616 NW2d 710 (2000) and People v Hanks, 276 Mich App 91; 740 NW2d 530 (2007). In Williams, the Court recognized that withholding biographical information about prospective jurors may interfere with a defendant’s rights to conduct meaningful voir dire and to be presumed innocent. Williams, 241 Mich App at 522-523. The Court explained that “[i] n order to successfully challenge the use of an ‘anonymous jury,’ the record must reflect that the parties have had information withheld from them, thus preventing meaningful voir dire, or that the presumption of innocence has been compromised.” Id. at 523. In both the Williams and Hanks cases, the jurors were identified by number during trial, but the defendants nonetheless had access to the jurors’ biographical information through their questionnaires. Williams, 241 Mich App at 523-524; Hanks, 276 Mich App at 94. Under the facts of Williams, at trial, the jurors were simply referred to by their juror numbers as opposed to their names, and the record did not otherwise support a conclusion that any biographical information was withheld from the parties. Williams, 241 Mich App at 523. This Court was not persuaded that the mere use of juror numbers, by itself, constituted the empaneling of an anonymous jury or violated a defendant’s due process rights. Id. This Court determined “[t]here [was] nothing to indicate that defendant’s ability to effectively examine the venire was compromised in any way.” Id. at 524. This Court further reasoned, in pertinent part, that the record did not show that the use of numbers in any way “undermined the presumption of innocence”:

-2- In addition, there is nothing in the record to indicate that the use of numbers undermined the presumption of innocence. There is no suggestion that jurors understood the use of numbers rather than names to be anything out of the ordinary. Thus, there was no suggestion that defendant’s trial was being handled in a special way, with the resulting implication that he was generally dangerous or guilty as charged. Other state appellate courts have declined to review claims of prejudice in the withholding of jurors’ names in the absence of any evidence in the record of prejudice. [Id.]

The Court in Williams, did not discern any reason to presume prejudice arising from the trial court’s actions. Id. at 525. Nonetheless, the Court cautioned trial courts regarding “the potential for prejudice” that could arise from the use of anonymous juries, stating that the procedure should be used only under circumstances in which the safety of jurors or the potential of harassment was implicated. Id. Even then, “appropriate safeguards should be carefully followed to assure a fair trial.” Id.

Similarly, in Hanks, this Court “strongly urge[d]” trial courts to advise the jury venire that any use of numbers instead of the names of the jurors was simply for logistical purposes and that the jury ought not to construe this action in any way negatively against the defendant. Hanks, 276 Mich App at 94. Also, the record did not yield any indication that the jurors thought that the trial court’s use of numbers was significant. Id. The Court in Hanks also reasoned that the trial court’s use of the anonymous jury was limited to the literal sense, the dangers of the anonymous jury were not present, and neither the defendant’s right to engage in a meaningful voir dire nor his right to the presumption of innocence was undermined. Id.

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Bluebook (online)
People of Michigan v. Howard Shane Hector, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-howard-shane-hector-michctapp-2025.