People of Michigan v. Steven Micheal Cook

CourtMichigan Court of Appeals
DecidedJune 27, 2024
Docket364181
StatusUnpublished

This text of People of Michigan v. Steven Micheal Cook (People of Michigan v. Steven Micheal Cook) 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. Steven Micheal Cook, (Mich. Ct. App. 2024).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 27, 2024 Plaintiff-Appellee,

v No. 364181 Calhoun Circuit Court STEVEN MICHEAL COOK, also known as LC No. 2019-001537-FC STEVEN MICHAEL COOK,

Defendant-Appellant.

Before: O’BRIEN, P.J., and M. J. KELLY and FEENEY, JJ.

PER CURIAM.

Defendant appeals as of right his jury trial convictions of one count of first-degree criminal sexual conduct (CSC-I), MCL 750.520b(1)(a); MCL 750.520b(2)(b) (penetration committed by an individual 17 years of age or older against an individual less than 13 years of age); and one count of second-degree criminal sexual conduct (CSC-II), MCL 750.520c(1)(a); MCL 750.520c(2)(b) (sexual contact by an individual 17 years of age or older against an individual less than 13 years of age). The trial court sentenced defendant to serve 25 to 50 years’ imprisonment for the CSC-I conviction and 71 months to 15 years’ imprisonment for the CSC-II conviction. We affirm.

I. Background

This case arises out of sexual assaults that defendant perpetrated on the daughters of his girlfriend when they lived together in Battle Creek. The mother testified that she met defendant in 2014, when her two daughters, NH and MH, were four and five years old. In the fall of 2018, NH reported to her counselor at school that defendant had touched her vagina. Thereafter, MH also disclosed that defendant touched her vagina and that his fingers penetrated her vagina.

Two years prior to these allegations coming to light, there was an incident between NH, MH and defendant’s son WC which had resulted in counseling for the family with Debra Ingle,

-1- M.S.W.1 At this counseling, WC stated that he and his sisters 2 had inappropriately touched each other, but when asked what he meant he said that he did not know. Ingle later expressed concern that both defendant and his girlfriend (NH and MH’s mother) may have coached their children regarding this counseling. Ingle never documented any claims of sexual assault or rape from NH or MH regarding WC.

The prosecutor charged defendant with one count of CSC-I and two counts of CSC-II. Defendant was found guilty of one count of CSC-I and one count of CSC-II related to MH’s claims of abuse, but the jury could not agree on a verdict for the count of CSC-II related to NH’s claims of abuse, and that charge was dismissed. Defendant now argues on appeal that the trial court erred by excluding evidence that NH and MH made prior false accusations of rape or other sexual misconduct against his son, WC. Defendant also claims that at least one juror improperly interpreted his choice not to testify in his own defense as a sign of guilt. We disagree with defendant’s allegations of error.

II. Analysis

A. Ingle’s Testimony

Pursuant to MRE 103(a)(2),3 a defendant may not predicate a claim of evidentiary error on the exclusion of evidence unless the defendant’s substantial rights were affected and the defendant made the substance of the evidence known to the court through an offer of proof. People v Thorne, 322 Mich App 340, 352; 912 NW2d 560 (2017). Defendant submitted testimony from Debra Ingle, who provided counseling to WC, NH, and MH in 2016. However, Ingle did not testify that NH or MH accused WC of sexual assault. Further, the trial court specifically ruled that, contrary to defendant’s similar claims in a child protective proceeding involving himself and WC, there was no evidence that NH or MH accused WC of sexual assault or any similar wrongdoing. Therefore, Ingle’s testimony contained no evidence of prior false claims of sexual assault, and is therefore irrelevant to defendant’s criminal case.

Defendant argues that Ingle’s testimony suggested that NH was coached by her mother when she made allegations about WC in 2016. Again, the record reflects that NH did not make allegations about WC; rather, the children only accused each other of “inappropriate” actions, such as going into each other’s rooms, but there were no allegations of rape or sexual assault. Moreover, Ingle’s observation during counseling that the mother may have coached NH about WC had no bearing on any claim involving defendant’s charges of criminal sexual conduct. Further, even if

1 Apparently, a Facebook post NH and MH’s mother made about boys sticking their hands into girls’ panties led to a Children’s Protective Services investigation and the children as well as the entire blended family receiving counseling with Ingle. 2 WC, NH and MH lived together in the same home for approximately 5 years but were not blood relatives. 3 The Michigan Rules of Evidence were substantially amended on September 20, 2023, effective January 1, 2024. See ADM File No. 2021-10, 512 Mich lxiii (2023). We rely on the version of the rules in effect at the time of trial.

-2- defendant could show that NH’s mother coached NH in a prior, unrelated, family court proceeding, defendant cannot show that he was prejudiced by the trial court’s exclusion of that evidence. See MRE 103(a)(2). The jury did not convict defendant of any claims involving NH, so Ingle’s testimony about any alleged coaching of NH had no bearing on the verdict for defendant’s sexual abuse of MH.

Defendant next argues that the trial court erred by failing to admit Ingle’s testimony from the child abuse and neglect adjudication hearing under MRE 804(b)(1). Again, we disagree.

We “review for an abuse of discretion a trial court’s decision to admit or exclude evidence,” and we review any preliminary legal questions of law de novo. People v Mann, 288 Mich App 114, 117; 792 NW2d 53 (2010). “The trial court abuses its discretion when its decision falls outside the range of principled outcomes . . . .” People v Lane, 308 Mich App 38, 51; 862 NW2d 446 (2014). MRE 804(b)(1) states that, if the declarant is unavailable, former testimony is not excluded as hearsay if the testimony “was given as a witness at another hearing of the same or a different proceeding, if the party against whom the testimony is now offered . . . had an opportunity and similar motive to develop the testimony by direct, cross, or redirect examination.” The parties do not dispute that Ingle was unavailable to testify at defendant’s criminal trial in 2022 because she died in 2021, so defendant is seeking to admit her testimony under an exception to the hearsay rule.

The neglect adjudication involving defendant’s parental rights to WC included Ingle’s testimony regarding NH’s and MH’s relationship with WC; again, this testimony contained no assertions of sexual abuse. In that earlier proceeding, defendant sought to show that during counseling with Ingle, NH’s mother coached NH and, therefore, she may have coached NH and MH to make the allegations against defendant.4 The record reflects that at the 2018 neglect proceedings involving WC and defendant, the parties had an opportunity to cross-examine Ingle at length about her observations during counseling with NH, MH, and WC. This may be enough to satisfy the hearsay exception under MRE 804(b)(1), but that does not make Ingle’s testimony relevant, which is always a requirement for admissibility. See MRE 402. “ ‘Relevant evidence’ means evidence having 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 401.

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Cite This Page — Counsel Stack

Bluebook (online)
People of Michigan v. Steven Micheal Cook, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-steven-micheal-cook-michctapp-2024.