People of Michigan v. Justin Amir House

CourtMichigan Court of Appeals
DecidedJune 11, 2026
Docket367024
StatusUnpublished

This text of People of Michigan v. Justin Amir House (People of Michigan v. Justin Amir House) 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. Justin Amir House, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 11, 2026 Plaintiff-Appellee, 3:09 PM

v No. 367024 Kent Circuit Court JUSTIN AMIR HOUSE, LC No. 22-005894-FC

Defendant-Appellant.

Before: REDFORD, P.J., and WALLACE and LIEVENSE, JJ.

PER CURIAM.

A jury convicted defendant of second-degree murder, MCL 750.317 and carrying a firearm during the commission of a felony (felony-firearm), MCL 750.227b. The trial court sentenced defendant to serve 14 to 40 years’ imprisonment for second-degree murder, to be served consecutive to two years’ imprisonment for the felony-firearm conviction. On appeal, defendant raises three issues: first, he received ineffective assistance of counsel; second, the trial court erred by excluding character evidence about the victim but admitting autopsy photographs; and third, the trial court erred when sentencing defendant. We affirm.

I. BACKGROUND

In March 2022, defendant’s father’s vehicle, a Honda Crosstour, was stolen. On March 12, 2022, defendant, his girlfriend, and their young child were driving and came across the stolen Honda. Defendant pulled in front of, and facing the Honda, at an intersection. An eyewitness, Christian Bethea, Jr., testified at trial that he was stopped at the red light immediately behind the Honda. The witness saw the car doors open on defendant’s vehicle; the Honda “slammed in reverse,” twice hitting Bethea’s vehicle; and four teenage males exited the Honda and ran away. Bethea saw that two of the teenagers had handguns. After the initial crash, Bethea used the camera on his phone to record defendant getting out of his vehicle and following the teenagers. Several other witnesses saw portions of the incident, including Emily Killmer, who was in a nearby car.

Killmer saw two of the teenagers run away with guns in their hands. Defendant’s girlfriend called 911. Defendant’s cousin, Ronald James, also drove by the scene and saw a teenager with a gun. Defendant ultimately shot and killed the 13-year-old victim. When police officers

-1- interviewed defendant, defendant reported that he heard someone say “bro, shoot him, he’s following us,” and he saw an individual in a red coat gesture “as if he was pulling out a weapon from his waist area or coat.” Defendant reported to the police that this is what made him draw his weapon and fire. Before trial, the defense moved to admit pictures and videos posted by the victim to his social media sites as character evidence of the victim and to present evidence that the victim was a member of a juvenile gang and that there were pictures on social media of the victim possessing firearms. Defendant claimed such evidence would “complete his theory of self- defense.” The trial court denied defendant’s motion to admit the evidence about the victim.

During trial, over defense counsel’s objections, the prosecution admitted two autopsy photographs of the victim. The jury found defendant guilty of second-degree murder and felony- firearm, and the trial court imposed sentenced as previously noted.

Defendant moved for a new trial or evidentiary hearing on the basis of ineffective assistance of counsel and for resentencing. Defendant submitted declarations from four individuals who stated that they would have been available to testify about defendant’s character for peacefulness. After making some changes to the offense variable scoring, the trial court denied defendant’s motions.

Defendant now appeals.

II. ANALYSIS

A. INEFFECTIVE ASSISTANCE OF COUNSEL

First, defendant argues that he received ineffective assistance of counsel when defense counsel did not present evidence of his character.

“Whether a defendant has been denied the effective assistance of counsel is a mixed question of fact and constitutional law.” People v Solloway, 316 Mich App 174, 187-188; 891 NW2d 255 (2016). We review for clear error a trial court’s factual findings and review de novo questions of constitutional law. People v Trakhtenberg, 493 Mich 38, 47; 826 NW2d 136 (2012). Clear error exists when this Court is left with a definite and firm conviction that the trial court made an error. People v Buie, 491 Mich 294, 315-316; 817 NW2d 33 (2012). Although defendant has preserved the issue, no evidentiary hearing has been held and, therefore, review is limited to errors apparent on the lower court record. See People v Jordan, 275 Mich App 659, 667; 739 NW2d 706 (2007). We do not interfere with a jury’s determination of witness credibility. See People v Kanaan, 278 Mich App 594, 619; 751 NW2d 57 (2008).

Defendant’s right to counsel is guaranteed by the United States and Michigan Constitutions. See US Const, Am VI; Const 1963, art 1, § 20. This right includes the right to the effective assistance of counsel. People v Cline, 276 Mich App 634, 637; 741 NW2d 563 (2007). To establish a claim of ineffective assistance of counsel, a defendant must show that: (1) counsel’s performance was deficient; and (2) the deficient performance prejudiced the defense. People v Taylor, 275 Mich App 177, 186; 737 NW2d 790 (2007). Defense counsel’s performance is deficient if it fell below an objective standard of professional reasonableness. Jordan, 275 Mich App at 667. A defendant bears a heavy burden to show that counsel made errors so serious that counsel was not performing as the counsel guaranteed by the Sixth Amendment, and a defendant

-2- must overcome a strong presumption that counsel’s performance constituted sound trial strategy. People v Carbin, 463 Mich 590, 599-600; 623 NW2d 884 (2001). Defense counsel’s performance prejudiced the defense if there is a reasonable probability that, but for counsel’s error, the result of the proceeding would have been different. Jordan, 275 Mich App at 667. “Defense counsel is given wide discretion in matters of trial strategy because many calculated risks may be necessary in order to win difficult cases.” People v Unger, 278 Mich App 210, 242; 749 NW2d 272 (2008). This Court does not substitute its judgment on matters of trial strategy or use the benefit of hindsight to assess counsel’s competence. Id. at 242-243.

At the time of defendant’s trial,1 Michigan Rule of Evidence (MRE) 401 provided that evidence was relevant if it had “any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.” MRE 404(a)(1) provided that evidence of a person’s character is not admissible to prove that he or she acted in conformity with that character, but one exception for that rule is that a criminal defendant may offer evidence of a pertinent character trait. MRE 404(a)(2). Under MRE 405(a), when character evidence is admissible, a party may prove it through testimony about the person’s reputation or in the form of an opinion. “On cross- examination, inquiry is allowable into reports of relevant specific instances of conduct.” MRE 405(a). Further, if character or a character trait is an essential element of a charge, claim, or defense, evidence about specific instances of the person’s conduct is admissible. MRE 405(b). A defendant may present evidence that he has a character trait that makes it less likely that he committed the charged offense. People v Roper, 286 Mich App 77, 93; 777 NW2d 483 (2009). Evidence that a defendant has a peaceful character is relevant to a charge involving violent conduct. People v Zitka, 335 Mich App 324, 341-342; 966 NW2d 786 (2020).

The trial court did not err by denying defendant a new trial or evidentiary hearing on the basis of ineffective assistance of counsel.

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People of Michigan v. Justin Amir House, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-justin-amir-house-michctapp-2026.