Self-defense; The Self-Defense Act; People v Riddle; Witness-interference defense; MCL 750.122(4); Credibility

The court rejected defendant’s self-defense arguments as to his second-degree murder conviction, and also held that the prosecution presented sufficient evidence to allow the jury to reject his defense under MCL 750.122(4) as to the witness-interference conviction. He was also convicted of CCW, FIP of ammunition and a firearm, felony-firearm, and threatening a witness. On appeal, the court first found his self-defense challenge to the witness-interference conviction “unpersuasive.” It noted that a defendant facing this charge “may raise an affirmative defense ‘that the conduct consisted solely of lawful conduct and that the defendant's sole intention was to encourage, induce, or cause the other person to testify or provide evidence truthfully[,]’” under MCL 750.122(4). The jury was presented with both “defendant’s claim that he was trying to get the witnesses to tell the truth as well as the prosecutor’s questions calling that explanation into question.” The court noted that “‘an appellate court must not interfere with the jury’s role in assessing the weight of the evidence and the credibility of the witnesses.’” As to the murder conviction, the “jury was presented with different accounts of the shooting and made its own credibility determinations in deciding who to believe and to what extent. Defendant may disagree with the outcome, but the record contains sufficient evidence from which a rational trier of fact could find that [his] actions were not in self-defense beyond a reasonable doubt. The jury was informed of the inconsistencies between the witnesses’ trial testimony and their prior statements. It also heard both parties’ competing interpretations of the surveillance footage and viewed the video itself, including the gap in the recording during which the shooting occurred.” Thus, it was “free to determine what the video showed and to infer what occurred during the missing portion of the recording in light of the trial testimony.” While defendant asserted “that the prosecutor’s witnesses were incredible because of their contradictory statements,” their credibility was for the jury to decide. Affirmed.