People of Michigan v. Marita Glynise Talley

CourtMichigan Court of Appeals
DecidedAugust 4, 2022
Docket356518
StatusUnpublished

This text of People of Michigan v. Marita Glynise Talley (People of Michigan v. Marita Glynise Talley) 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. Marita Glynise Talley, (Mich. Ct. App. 2022).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED August 4, 2022 Plaintiff-Appellee,

v No. 356518 Oakland Circuit Court MARITA GLYNISE TALLEY, LC No. 2018-267313-FC

Defendant-Appellant.

Before: SHAPIRO, P.J., and RICK and GARRETT, JJ.

PER CURIAM.

Following a jury trial, defendant was convicted of first-degree premeditated murder, MCL 750.316(1)(a).1 Defendant moved for a new trial premised on ineffective assistance of counsel, and in support of that claim she moved for in camera review of the victim’s medical records, which the trial court denied. Defendant filed an interlocutory appeal of that decision, and in lieu of granting her application for leave to appeal, we entered an order peremptorily reversing the trial court.2 The Supreme Court vacated this Court’s order and remanded to us for plenary review.3 For the reasons stated in this opinion, we now affirm.

I. BACKGROUND

This case arises from the May 11, 2018 shooting death of William Bell, Jr., at his home in Pontiac, Michigan. The basic facts are as follows. Defendant moved in with Bell in October 2016

1 Defendant was also convicted of one count of unlawful possession of a firearm by a felon (felon- in-possession), MCL 750.224f; and two counts of possession of a firearm during the commission of a felony (felony-firearm), MCL 750.227b. She was sentenced to life without parole for the murder conviction. 2 People v Talley, unpublished order of the Court of Appeals, entered April 13, 2021 (Docket No. 356518). 3 People v Talley, ___ Mich ___ (2021) (Docket No. 162974).

-1- when she needed a place to live and at some point, they became romantic partners. Bell’s father testified that in May 2018 Bell confided that he no longer wanted to be in a relationship with defendant and that he wanted her to move out, but she did not do so. Bell’s brother gave similar testimony about Bell wanting to end his relationship with defendant. Near midnight on May 11, 2018, defendant made a 911 emergency call in which she reported that Bell was dead. In the audio recording of the 911 call that was played for the jury, defendant claimed that Bell had pointed a gun at her and that she had taken it from him and shot him multiple times. The call disconnected and the dispatcher called defendant back. While they were speaking, the dispatcher heard a loud bang. Defendant explained that she thought Bell was reaching for the gun, and so she shot him again.

Police arrived at the scene to find Bell deceased on the couch, in a slumped-seating position with a half-filled, uncapped water bottle between his legs. Officers testified that there was no wetness or spillage from the water bottle on the surrounding area. A TV remote control was tucked under Bell’s right leg, there were two shell casings near his buttocks, several shell casings on the floor in front of him, and no signs of struggle in the room. It was determined that Bell was shot 11 times. A toxicology screen showed that Bell had a blood alcohol content of .02 at the time of his death and that there were no drugs, legal or illicit, in his system.

Defendant testified at trial and claimed self-defense. According to defendant, on the night of the killing, she and Bell had purchased a half gallon of vodka, which Bell was drinking fairly heavily. Defendant testified that Bell became rude and broke her phone and then “pulled the gun out” and threatened to kill her. She lunged for the gun and wrestled with Bell on the couch to get control of the gun. She finally got the gun and was walking backward when Bell jumped up toward her, at which point she shot him several times. The prosecution argued that the evidence showed that defendant shot Bell as he sat resting, half-asleep on the couch.

Defendant appealed her convictions to this Court, and we granted her motion to remand for an evidentiary hearing on her claims of ineffective assistance of counsel.4 Relevant to this appeal, defendant argues that her trial counsel was ineffective for failing to investigate whether the interaction between Bell’s seizure medication and his consumption of alcohol could have caused him to act aggressively toward defendant. At trial, Bell’s father and brother testified that Bell regularly took seizure medication to control his epilepsy. As noted, however, the medical examiner reported no prescription medications were in Bell’s system at the time of his death. On remand, defendant moved the trial court for an in camera inspection of Bell’s medical records to determine the name of his seizure medication.

As a preliminary step to deciding the motion, the trial court ordered the medical examiner to produce a list of all the medications tested for in the toxicology examination. The court also granted defendant’s motion for funds to retain an expert witness regarding the effects of seizure medication. Defendant’s expert, Dr. Gerald A. Shiener, reviewed the list of the substances tested for by the medical examiner and reported that there were more than 10 seizure medications available at the time of Bell’s death, but the medical examiner only tested for three of them. Dr.

4 People v Talley, unpublished order of the Court of Appeals, entered June 17, 2020 (Docket No. 350178).

-2- Shiener stated some of these medications, when mixed with alcohol, can cause aggression. The parties submitted supplemental briefs, and after a hearing the trial court denied the motion for an in camera review of Bell’s medical records.

II. ANALYSIS

A trial court’s decision regarding a motion for an in camera review of records is reviewed for an abuse of discretion. People v Davis-Christian, 316 Mich App 204, 207; 891 NW2d 250 (2016). “The trial court abuses its discretion when its decision falls outside the range of principled outcomes or when it erroneously interprets or applies the law.” People v Jack, 336 Mich App 316, 321; 970 NW2d 443 (2021) (quotation marks and citation omitted).

Bell’s medical records are protected by the physician-patient privilege. See MCL 600.2157. In People v Stanaway, 446 Mich 643, 659-650; 521 NW2d 557 (1994), the Supreme Court established the following procedure for when a criminal defendant seeks discovery of privileged material:

We hold that where a defendant can establish a reasonable probability that the privileged records are likely to contain material information necessary to his defense, an in camera review of those records must be conducted to ascertain whether they contain evidence that is reasonably necessary, and therefore essential, to the defense. Only when the trial court finds such evidence, should it be provided to the defendant.[5]

In the posttrial context, “[e]vidence is material only if there is a reasonable probability that the trial result would have been different, had the evidence been disclosed.” People v Fink, 456 Mich 449, 454; 574 NW2d 28 (1998).6

A.

A review of the trial testimony regarding Bell’s use of prescription seizure medication is necessary for resolution of this issue. Bell’s father, William Spencer Bell, Sr., testified that Bell’s seizures began when he was about 17 years old. When asked what medications his son was prescribed for the epilepsy, William reported: “It’s a common drug for people that have epilepsy or seizures. It’s—I can’t think of the name, I think it started with an E or something. I don’t know.” With respect to his son’s compliance with taking the medication, William stated:

I would say almost 99 percent. Occasionally he would forget, because the medication made him a little off balance. They was giving him, in my opinion, too much.

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Related

People v. Stanaway
521 N.W.2d 557 (Michigan Supreme Court, 1994)
People v. Fink
574 N.W.2d 28 (Michigan Supreme Court, 1998)
People v. Davis-Christian
891 N.W.2d 250 (Michigan Court of Appeals, 2016)

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People of Michigan v. Marita Glynise Talley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-marita-glynise-talley-michctapp-2022.