People of Michigan v. Sade Nicole Keith

CourtMichigan Court of Appeals
DecidedApril 9, 2025
Docket364843
StatusUnpublished

This text of People of Michigan v. Sade Nicole Keith (People of Michigan v. Sade Nicole Keith) 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. Sade Nicole Keith, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED April 09, 2025 Plaintiff-Appellee, 11:25 AM

v No. 364843 Wayne Circuit Court SADE NICOLE KEITH, LC No. 21-000487-01-FH

Defendant-Appellant.

Before: GARRETT, P.J., and K. F. KELLY and SWARTZLE, JJ.

PER CURIAM.

Five-year-old PJ died after he was ejected from a vehicle. The driver of the vehicle, defendant, Sade Nicole Keith, had an extremely high blood alcohol content (BAC) and her driver’s license had been suspended. PJ was ejected from Keith’s vehicle after she ran a red light, and her SUV collided with another vehicle. Keith appeals by right her jury-trial convictions of involuntary manslaughter, MCL 750.321; operating a motor vehicle while license suspended (OWLS) causing death, MCL 257.904(4); three counts of second-degree child abuse, MCL 750.136b(3); and four counts of operating a motor vehicle while intoxicated (OWI) with an occupant less than 16 years old, MCL 257.625(7)(a)(ii). The trial court sentenced Keith to 8 years and 4 months to 15 years’ imprisonment for the involuntary manslaughter and OWLS causing death convictions, 5 years and 11 months to 10 years’ imprisonment for each second-degree child abuse conviction, and 180 to 365 days’ imprisonment for each conviction of OWI with an occupant less than 16 years old. We conclude that the prosecutor’s use of Keith’s prearrest and postarrest silence did not violate her Fifth Amendment rights, defense counsel did not render ineffective assistance of counsel and did not deny Keith her right to maintain her innocence at trial, and the trial court properly scored Keith’s sentencing guidelines. Accordingly, we affirm.

I. FACTUAL BACKGROUND

Keith’s convictions stem from a motor-vehicle collision that occurred after Keith ran a red light. Inside the vehicle with Keith were her two children, one-year-old RP and six-year-old LK, and her friend’s two children, three-year-old JJ and five-year-old PJ. It does not appear that LK, JJ, or PJ were in car seats or wearing seat belts when the accident occurred. PJ was ejected from

-1- the SUV during the collision and suffered fatal injuries. The other children suffered only minor injuries. Keith’s driver’s license had been suspended, and she was driving approximately 20 miles per hour over the speed limit when the accident occurred. A blood draw a few hours after the accident indicated that Keith’s BAC was 0.332.

The prosecution charged Keith with one count of second-degree murder, MCL 750.317; one count of operating while intoxicated causing death or a serious impairment of body function (OWI causing death), MCL 257.625(4); one count of OWLS causing death; three counts of second-degree child abuse; and four counts of OWI with an occupant under 16 years old. Keith’s theory of defense at trial was that she lacked the requisite mental state for second-degree murder and that the jury should instead consider the lesser-included offense of involuntary manslaughter. The jury acquitted Keith of second-degree murder and OWI causing death; it convicted her of involuntary manslaughter and the remaining charged offenses. She now appeals by right.

II. ALLEGED FIFTH AMENDMENT VIOLATIONS

Keith argues that the prosecutor committed prosecutorial misconduct1 and violated her Fifth Amendment rights by commenting on her prearrest and postarrest silence during closing argument. She also argues that she was denied the effective assistance of counsel when her attorney failed to object to the prosecutor’s comments and failed to move to suppress evidence. We address each argument in turn.

A. STANDARDS OF REVIEW

We review de novo preserved questions of constitutional law. People v Williams, 475 Mich 245, 250; 716 NW2d 208 (2006). We review for clear error a trial court’s factual determinations. Id. “Clear error exists when the reviewing court is left with the definite and firm conviction that a mistake has been made.” People v Anderson, 284 Mich App 11, 13; 772 NW2d 792 (2009) (quotation marks and citation omitted).

“[T]o preserve an issue of prosecutorial misconduct, a defendant must contemporaneously object and request a curative instruction.” People v Isrow, 339 Mich App 522, 529; 984 NW2d 528 (2021) (alteration in original; quotation marks and citation omitted). Because Keith did not do so, she failed to preserve her prosecutorial misconduct arguments for our review. See id. We review unpreserved issues “for plain error affecting substantial rights.” People v Spaulding, 332 Mich App 638, 652; 957 NW2d 843 (2020).

1 Although “prosecutorial misconduct” is a commonly accepted term of art in criminal appeals, it is a misnomer when referring to allegations that do not involve violations of the rules of professional conduct or illegal activity. People v Cooper, 309 Mich App 74, 87-88; 867 NW2d 452 (2015). Less egregious conduct involving inadvertent or technical error is more properly characterized as “prosecutorial error.” Id. at 88. Nonetheless, because Keith uses the term “prosecutorial misconduct,” we will do the same.

-2- To avoid forfeiture under the plain error rule three requirements must be met: 1) error must have occurred, 2) the error was plain, i.e., clear or obvious, and 3) the plain error affected substantial rights. Reversal is warranted only if the plain error resulted in the conviction of an innocent defendant or if the error seriously affected the fairness, integrity, or public reputation of judicial proceedings independent of the defendant’s innocence. [Id. at 653 (quotation marks and citation omitted).]

Keith preserved her ineffective assistance of counsel argument for this Court’s review by moving for a new trial and a Ginther2 hearing in the trial court. See People v Head, 323 Mich App 526, 538-539; 917 NW2d 752 (2018). Because an evidentiary hearing was not held, our review is limited to mistakes apparent from the record. People v Muhammad, 326 Mich App 40, 63; 931 NW2d 20 (2018). “A claim of ineffective assistance of counsel presents a mixed question of fact and constitutional law. All findings of fact are reviewed for clear error, while the legal questions are reviewed de novo.” Isrow, 339 Mich App at 531 (quotation marks and citations omitted).

B. LEGAL PRINCIPLES

A prosecutor commits misconduct if they abandoned their responsibility to seek justice and, by doing so, the defendant is denied a fair and impartial trial. People v Lane, 308 Mich App 38, 62; 862 NW2d 446 (2014).

Issues of prosecutorial misconduct are decided case by case, and this Court must examine the entire record and evaluate a prosecutor’s remarks in context. The propriety of a prosecutor’s remarks depends on all the facts of the case. A prosecutor’s comments are to be evaluated in light of defense arguments and the relationship the comments bear to the evidence admitted at trial. [People v Dobek, 274 Mich App 58, 63-64; 732 NW2d 546 (2007) (quotation marks and citations omitted).]

In order to establish ineffective assistance of counsel, a defendant must show that: (1) “counsel’s performance fell below an objective standard of reasonableness under prevailing professional norms” and (2) a reasonable probability exists that, “but for counsel’s error, the result of the proceedings would have been different.” People v Abcumby-Blair, 335 Mich App 210, 228; 966 NW2d 437 (2020). “A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. (quotation marks and citations omitted).

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People of Michigan v. Sade Nicole Keith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-sade-nicole-keith-michctapp-2025.