People of Michigan v. Rufus Chappell

Michigan Court of Appeals·Decided July 22, 2026·No. 372286·Unpublished

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED July 22, 2026

Plaintiff-Appellee, 12:14 PM

V No. 372286 Wayne Circuit Court

RUFUS CHAPPELL, LC No. 23-003320-01-FH

Defendant-Appellant.

Before: MALDONADO, P.J., and RIORDAN and YOUNG, JJ.

PER CURIAM.

Defendant appeals as of right his jury-trial conviction of embezzlement by an agent or trustee of $20,000 or more but less than $50,000, MCL 750.174(5)(a), for which he was sentenced to three years’ probation and restitution of $47,214.85. We affirm.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Defendant began his employment with the Unemployment Insurance Agency (UIA) in 1979. On October 1, 2015, defendant became a UIA unemployment insurance examiner. As a UIA examiner, defendant’s duties included attending hearings on denied unemployment claims as the state’s representative. Defendant’s direct supervisors from 2015 to 2019 were Tom Sanfilippo and Rochelle Washington. While defendant was employed and ordinarily worked at Cadillac Place in Detroit, he also attended hearings in Southfield.

On April 4, 2004, defendant signed the state’s Motor Vehicle Driver Agreement, which included the following term: “I will agree I will not operate a State of Michigan motor vehicle without possession of a valid Michigan driver’s license with proper endorsements when applicable.” The agreement also included a provision mandating that motor-pool vehicles be used only for official state business. On May 16, 2018, defendant signed an acknowledgment of the UIA’s official policies, which included immediately notifying his supervisor if his driver’s license was suspended.

Defendant reserved vehicles from the state’s motor pool multiple times from August 17, 2015 to January 16, 2019, with each use being billed to the UIA from Vehicle Travel Services

(VTS). Defendant’s license was suspended at least twice between 2016 and 2020. Eventually, Jamie Mathews, a statewide travel coordinator, was alerted to defendant’s suspended license and disabled his UIA driving privileges. Mathews reviewed the fuel and reservation records for vehicles reserved under defendant’s employee identification number, which indicated suspiciously high figures.

Karmen Robinson, a labor relations specialist with the Department of Talent and Economic Development, investigated defendant for allegations of driving a state motor-pool vehicle with a suspended license. Robinson interviewed defendant’s supervisors and reviewed the fuel records, reservation records, and defendant’s hearing schedules. Robinson’s review indicated that defendant reserved a vehicle from the motor pool for a total of 1,212 days, with 889 days not containing a hearing for the UIA; drove a total of 175,789 miles; and incurred $47,214.85 in total costs billed to the UIA. Robinson interviewed defendant, who appeared with his union representative. Washington also was present and took notes. At the interview, defendant claimed that he used the motor pool for employment purposes and was given permission by his former supervisor. Ultimately, defendant was charged with embezzlement as noted.

At trial, defendant’s managers confirmed that he was never given permission nor sought permission to use the motor pool in the manner allegedly used by him. The managers also confirmed that they never disclosed defendant’s employee identification number to anyone else.1 David Hofmeister, the motor pool and acting fleet operations manager for the VTS, explained the process for reserving, checking out, and returning a vehicle from the motor pool. He explained that the motor-pool vehicles were leased, and VTS would charge use and mileage rates to recoup the costs of operating the motor pool. As noted, the rates charged on behalf of defendant were $47,214.85 for the time period in question.

During trial, defendant and the prosecutor were provided with Washington’s notes from defendant’s interview with Robinson. Defendant moved to suppress his statements from the interview because of late disclosure of the notes, which violated the discovery order. The prosecutor explained that he received the notes the same day as defendant and was unaware of their existence until that point. The trial court ruled that the notes were not intentionally suppressed and that defendant was not surprised by the notes because the notes discussed the contents of his interview, and Robinson testified about the interview at the preliminary examination. However, the trial court delayed Robinson’s testimony until the next trial day so defense counsel could review the notes.

Before Robinson testified, the trial court held an evidentiary hearing regarding the notes.

Robinson confirmed that Washington took notes during the interview and stated that she (Robinson) also took notes. Robinson used both notes to generate her report, and the notes were meant to be destroyed. Robinson could not explain why the notes in this case were not destroyed. Robinson admitted that she failed to submit the notes to the prosecution, stating that she overlooked them. After an off-the-record discussion, Robinson testified and explained the steps in her

1 The employee identification number is used to check out and drive a state motor-pool vehicle.

investigation. Defendant was found guilty as charged and sentenced as delineated above. This appeal followed.

II. JURY INSTRUCTION

Defendant argues that the trial court erred by failing to sua sponte instruct the jury on the lesser included offense of embezzlement of more than $1,000 but less than $20,000, MCL 750.174(4)(a). Defendant waived this issue.

Waiver is “the intentional relinquishment or abandonment of a known right.” People v Kowalski, 489 Mich 488, 503; 803 NW2d 200 (2011) (quotation marks and citation omitted). “A waiver extinguishes the right, as well as any right to pursue an alleged error on appeal.” People v King, 512 Mich 1, 9; 999 NW2d 670 (2023).

After the trial court read the final jury instructions, it inquired whether the parties were satisfied. Defense counsel replied: “I’m satisfied, Judge.” Defense counsel also expressly stated that he had no objection to the verdict form. Thus, because defendant expressed his satisfaction with the trial court’s recitation of the jury instructions, defendant has waived this issue, and we will not consider it. See Kowalski, 489 Mich at 503 (“When defense counsel clearly expresses satisfaction with a trial court’s decision, counsel’s action will be deemed to constitute a waiver.”).2

III. DISCOVERY VIOLATION

Defendant argues that the trial court’s remedy for the prosecution’s discovery violation was not sufficient. We disagree.

A. STANDARD OF REVIEW

“We review a trial court’s decision regarding the appropriate remedy for a discovery violation for an abuse of discretion.” People v Dickinson, 321 Mich App 1, 17; 909 NW2d 24 (2017). “An abuse of discretion occurs when the trial court chooses an outcome that is outside the range of principled outcomes.” Id. at 18. “To obtain relief for a discovery violation, the defendant must establish that the violation prejudiced him or her.” Id. at 17-18.

B. ANALYSIS

“There is no general constitutional right to discovery in a criminal case.” People v Elston, 462 Mich 751, 765; 614 NW2d 595 (2000). Late disclosure of evidence by the prosecution under MCR 6.201(J) is a nonconstitutional violation. See id. MCR 6.201(J) states:

If a party fails to comply with this rule, the court, in its discretion, may order the party to provide the discovery or permit the inspection of materials not previously disclosed, grant a continuance, prohibit the party from introducing in

2 Defendant raises a parallel claim that defense counsel was ineffective in this regard, which we address infra.

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