In People v Lyles, No. 153185, the Michigan Supreme Court reversed the Court of Appeals and reinstated the defendant’s conviction for first degree murder. The Court did this despite having already concluded that the trial court erred in failing to instruct the jury that the defendant’s good-character evidence could create a reasonable doubt. But the Court held that this error was harmless, and that the outcome at trial would not have been different even if the jury had been properly instructed.
In the late 1970’s and early 1980’s, the defendant lived in his then-girlfriend’s home with her two daughters. But the relationship soured and he moved out. Shortly before that, his girlfriend had a male relative move in. A few months later, in 1983, the relative was stabbed to death in the middle of the night. The defendant moved out of Michigan and was not heard from until 2012, when he was discovered living with a relative in Oak Park.
The defendant was arrested and tried for the murder of his ex-girlfriend’s relative. At trial, the prosecution introduced evidence that the perpetrator was familiar with the house where the murder took place and that the defendant had lived there for about four years. There was also circumstantial evidence identifying the defendant on the night of the murder. The rest of the prosecution’s evidence largely concerned the defendant’s alleged bad-character, namely, that he had abused his ex-girlfriend. The defendant countered with evidence of his own good-character, which the Supreme Court noted “was both substantively weaker and was offered by witnesses who had little contact with defendant during the relevant time period and who no longer lived in the same city.”
Before jury deliberation, the trial court denied the defendant’s request for a required instruction that his good-character evidence alone could create a reasonable doubt. The Supreme Court concluded that this was in error. But as a preserved, nonconstitutional error, it was subject to harmless-error review. And the Court concluded that because the prosecution’s bad-character evidence “far outweighed” the defendant’s good-character evidence and the other supporting evidence introduced at trial, the trial court’s error was not outcome determinative, and therefore was harmless. The conviction was reinstated.
Justice McCormack—joined by Justices Viviano and Bernstein—authored a 33-page dissent. The dissent underwent a thorough analysis of the evidence offered at trial, the difficulty presented by harmless-error review, and the majority’s application of the standard. Justice McCormack noted that because the murder was 30 years old, the trial turned heavily on credibility and character. He concluded that because the jury was instructed on the weight of the prosecution’s evidence concerning this matter, but not the defendant’s, the Court should have remanded for a new trial.
