e-Journal Summary

e-Journal Number : 84405
Opinion Date : 09/18/2025
e-Journal Date : 10/07/2025
Court : Michigan Court of Appeals
Case Name : People v. Doyle
Practice Area(s) : Criminal Law
Judge(s) : Per Curiam – Cameron, Murray, and Korobkin
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Issues:

Ineffective assistance of counsel; Failure to request defense of others instruction; Request for a involuntary manslaughter instruction; Plea negotiations; Lafler v Cooper

Summary

Concluding that defendant was not entitled to a new trial on the basis that counsel was ineffective, the court affirmed. He was convicted of first-degree murder, FIP, and felony-firearm. The court held that defendant was “not entitled to a new trial on the basis that counsel was ineffective for failing to request a jury instruction on defense of others and for proceeding to trial on a flawed understanding of homicide law by requesting the involuntary manslaughter instruction.” It concluded that because “the self-defense instructions provided referenced the defense of others, and the defense-of-others instruction would have been nearly identical to that provided for self-defense, . . . the instructions given did not exclude from consideration defendant’s defense-of-others justification for the shooting.” Given that determination, based on “the dearth of evidence contradicting [his] account of the day of the shooting, defense counsel’s argument on self-defense, and the jury’s conviction of defendant for first-degree murder on the basis of the evidence despite the self-defense instruction,” the court held defendant failed to show “that ‘but for counsel’s deficient performance, a different result would have been reasonably probable.’” The same was true for his “assertion that defense counsel was ineffective as a result of her flawed understanding of homicide law—namely, requesting the involuntary manslaughter instruction and addressing involuntary manslaughter in her closing argument.” The prosecution conceded, and the court agreed, “that defense counsel’s request for an involuntary manslaughter instruction and discussion of involuntary manslaughter in her closing argument demonstrated deficient performance.” But defendant “failed to establish that, had defense counsel not incorrectly requested the involuntary manslaughter instruction, and discussed voluntary manslaughter instead, the outcome of the trial would have been different.” Further, the court rejected his “argument that defense counsel was ineffective during plea negotiations, and that the trial court abused its discretion when it denied his request for an evidentiary hearing.”

Full PDF Opinion