People of Michigan v. William Elliott Blander

CourtMichigan Court of Appeals
DecidedJuly 15, 2025
Docket366048
StatusUnpublished

This text of People of Michigan v. William Elliott Blander (People of Michigan v. William Elliott Blander) 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. William Elliott Blander, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED July 15, 2025 Plaintiff-Appellee, 2:23 PM

v No. 366048 Oakland Circuit Court WILLIAM ELLIOTT BLANDER, LC No. 2020-275584-FH

Defendant-Appellant.

Before: LETICA, P.J., and MURRAY and PATEL, JJ.

PER CURIAM.

Defendant appeals as of right his jury-trial convictions of assault with intent to commit great bodily harm less than murder by strangulation (assault by strangulation), MCL 750.84(1)(b), and two counts of third-degree criminal sexual conduct (CSC-III), MCL 750.520d(1)(b)(force or coercion).1 The trial court sentenced him to concurrent terms of 9 to 20 years’ imprisonment for the assault by strangulation conviction and 10 to 15 years’ imprisonment for each CSC-III conviction. We affirm.

I. FACTUAL AND PROCEDURAL HISTORY

Defendant’s convictions arise from his relationship with RV. Defendant and RV became intimately involved after they met at a jobs’ program. RV subsequently started to question the relationship after learning things about defendant from his family and after seeing defendant discipline RV’s five-year-old son.

On June 9, 2020, RV still kept in contact with defendant even though she characterized the intimate part of their relationship as finished. At defendant’s request, RV drove her minivan to Bloomfield in the afternoon to pick up defendant from work. They drove around and talked, and defendant sought to continue the intimate relationship.

1 Defendant was acquitted of one count of CSC-III.

-1- They also drove to defendant’s cousin’s home where RV heard a conversation between the men that made her uncomfortable. When defendant’s cousin asked for beer from a local store, RV volunteered to pick it up because it would give her an opportunity to leave; however, defendant accompanied RV to the store. And they dropped the beer off at the cousin’s home.

RV began to drive her van when defendant expressed anger about RV’s earlier contact with an ex-boyfriend. Defendant threatened RV with a knife, but then began to strangle her with his hands. RV could not breathe or scream and pushed herself out of her vehicle to escape defendant’s grasp. RV next recalled waking up on the pavement with an injured ankle and blood streaming from her forehead.

Defendant attempted to convince RV that she had been “jumped” and that they had to leave because the police were on their way. Defendant pushed RV into the van and urged her to get in the back because he did not want anyone to see her condition. In the mirror, RV saw that she was bleeding from her head and nearly used an entire roll of paper towel to absorb the blood. RV tried to convince defendant to take her to a hospital because she was dizzy and weak. Although defendant said he would drive her to the hospital, he instead engaged in sexual relations with RV in the van despite her refusal. Defendant then parked on a Pontiac street near his female cousin’s house. Defendant dozed off, but woke anytime RV moved. RV did not attempt to sleep because she feared what defendant might do to her and thought she had a concussion. And, due to her injured ankle, RV was unable to run away.

The next morning, RV asked defendant to go to a gas station for water and cigarettes. Once there,2 defendant asked a young man to purchase those items in the store; however, the young man was unable to buy the cigarettes. Defendant eventually entered the store. RV managed to get to the driver’s seat, close the door, and lock it. Defendant ran out of the gas station, pounded on the window, and cursed at RV, but she was able to drive away.

RV went to her cousin’s home where a 911 call was placed. When the police arrived, RV’s adult and young cousins were present. RV disclosed the physical assault to the police. She did not initially reveal the sexual assault, explaining that her cousins disapproved of defendant, and she was embarrassed to admit what had happened in front of the young cousins. Photographs of RV’s injuries were taken.

Ultimately, RV did disclose the sexual assaults to the police and participated in sexual assault and strangulation examinations at HAVEN within two days of the assault. At trial, RV also testified about a prior assaultive act by defendant upon her in February 2020 that left her with a black eye as well as the events that occurred in June 2020.

At trial, MS, another woman who was dating defendant in May 2020, testified about a recent assault upon her by defendant. On June 6, 2020, MS was driving her car with defendant as a passenger. Defendant criticized the manner of MS’s driving and threatened to kill her. She decided to pick up food from a local restaurant and perform the delivery. In the car, defendant grabbed MS around the neck and arm. After MS bent defendant’s finger back, defendant released

2 Corroborating video evidence from the gas station was admitted at trial.

-2- her. Defendant then jumped into the driver’s seat and threatened to hit MS with the car. MS was able to flee into a local business and call the police. Her injuries were also photographed.

Additionally, a sexual assault nurse examiner (SANE), sheriff’s deputies, and the investigating sergeant testified. Defendant represented himself for the majority of the trial with two attorneys serving as advisory counsel.3 After defendant unsuccessfully tried to elicit testimony during his cross-examination of the investigating sergeant, he asked that advisory counsel represent him, acknowledging that counsel would handle the case to completion. Despite defendant’s contention that the sexual relations with RV were consensual and his attempt to file a complaint that RV had made a false police report against him, the jury convicted defendant of the assault by strangulation charge and two counts of CSC-III.

II. OTHER-ACTS EVIDENCE

Defendant first alleges that the trial court erred in admitting prior assaultive acts under MCL 768.27b and failed to conclude that the probative value of this evidence was substantially outweighed by the danger of unfair prejudice. We disagree.

“To preserve an evidentiary issue for review, a party opposing the admission of evidence must object at trial and specify the same ground for objection that it asserts on appeal.” People v Thorpe, 504 Mich 230, 252; 934 NW2d 693 (2019) (footnote omitted). When the preserved error is nonconstitutional, it is subject to harmless-error review. Id.; see also MCL 769.26 (“No judgment or verdict shall be set aside or reversed or a new trial be granted by any court of this state in any criminal case, on the ground of . . . improper admission or rejection of evidence . . . unless in the opinion of the court, after an examination of the entire cause, it shall affirmatively appear that the error complained of has resulted in a miscarriage of justice.”). If the error is constitutional or nonconstitutional and unpreserved, the defendant must demonstrate plain error that affected substantial rights. Thorpe, 504 Mich at 252. “The reviewing court should reverse only when the defendant is actually innocent or the error seriously affected the fairness, integrity, or public reputation of judicial proceedings.” Id. at 252-253 (footnote omitted).

Before trial, the prosecutor filed a notice of intent to introduce other-acts evidence, and defendant filed a response opposing their introduction. Therefore, this issue is preserved.4

3 Although the trial court allowed defendant to waive the right to counsel, it prohibited defendant from questioning his victims, RV and MS. Instead, defendant’s advisory counsel performed those examinations.

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Bluebook (online)
People of Michigan v. William Elliott Blander, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-william-elliott-blander-michctapp-2025.