People of Michigan v. Nadeem Yousaf Rajput

Citation: Not availableDocket: 158866

Court: Michigan Supreme Court; January 23, 2020; Michigan; State Supreme Court

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Nadeem Y. Rajput was convicted of second-degree murder in the Wayne Circuit Court after a confrontation that resulted in the death of the victim. The incident began when the victim, driving a red Malibu, and her boyfriend fired at Rajput's vehicle, prompting Rajput and his passenger, Haus, to seek out the Malibu. Upon locating it, an argument ensued, leading to multiple gunshots and the victim's death. Rajput claimed Haus shot the victim in self-defense, arguing that the victim reached for a gun. He requested a self-defense jury instruction, which was denied by the trial court based on past precedent, asserting that defendants claiming another person's guilt are not entitled to such instructions. Additionally, the court excluded testimony from Pierre Carr, which suggested the victim was encouraged to shoot. The jury acquitted Rajput of first-degree murder and felony-firearm but convicted him of second-degree murder. Despite a guideline range of 225 to 375 months, the trial court sentenced him to 46 to 95 years. Rajput appealed, and the Court of Appeals upheld the trial court's decisions regarding the jury instruction and the exclusion of Carr's testimony, but disagreed on the reasoning related to the self-defense instruction, stating Rajput and Haus were the initial aggressors. The Michigan Supreme Court unanimously held that the trial court erred in denying the self-defense instruction, emphasizing that jury instructions must allow for a defendant's theory of self-defense if supported by evidence. The Supreme Court also found fault with the Court of Appeals for improperly determining that Rajput was the initial aggressor, noting his intention was to inquire about the earlier shooting rather than to harm the victim.

Defendant Nadeem Yousaf Rajput claimed that individuals in a red Malibu had previously shot at a vacant home next to his residence. He contended that during the confrontation with the victim, Lakeisha Henry, the victim possessed a gun, which was later corroborated by police finding a firearm in her car. The jury was tasked with determining whether defendant and Haus were the initial aggressors or had the opportunity to flee, as defendant presented sufficient evidence for his self-defense claim. The Court of Appeals incorrectly upheld the denial of defendant’s request for a self-defense instruction. 

The Michigan Rules of Evidence (MRE) state that relevant evidence, which can influence the determination of a case, is admissible. The Court of Appeals erred in deeming testimony from Pierre Carr irrelevant, as it was critical to the self-defense issue, specifically whether the victim reached for the gun when instructed by Dewayne Clay to "shoot, shoot." The testimony had probative value, suggesting that the victim may have reached for the firearm, which could support Haus's self-defense argument. The Court of Appeals also made an erroneous factual finding regarding the initial aggressor status of defendant and Haus, further invalidating its ruling on the relevance of Carr’s testimony. The decision was reversed and remanded back to the Court of Appeals.

Defendant was convicted of second-degree murder (MCL 750.317) and sentenced to 46 to 95 years in prison. The Court of Appeals upheld the trial court's decisions regarding the self-defense instruction and the relevance of Carr’s testimony, concluding that the defendant and Haus were the initial aggressors and had the option to flee. However, the higher court reversed this decision, stating that the trial court erred by denying the self-defense instruction based on the premise that Haus's actions precluded it. It clarified that an aider and abettor can assert a self-defense claim if the principal acted in self-defense. The trial court's reasoning was deemed a legal error constituting an abuse of discretion. Additionally, the Court of Appeals was found to have improperly determined that the defendant and Haus were the initial aggressors, as the defendant contended he pursued the victim to understand the shooting incident rather than to harm her. The summary emphasized that a defendant must be granted a self-defense instruction if supported by evidence, and the prosecution holds the burden to disprove such a defense beyond a reasonable doubt. The case was remanded for further consideration in light of these findings.

The Court of Appeals incorrectly affirmed the denial of the defendant's self-defense instruction request by failing to substantiate its claim that the defendant could have fled during the confrontation with the victim. The defendant asserted that the victim reached for a gun, and evidence, including the discovery of a gun in the victim's car, supported his account. The court acknowledged that the determination of whether the defendant and Haus were the initial aggressors or had the option to flee should have been left to the jury, as the defendant met his burden of proof for self-defense.

Regarding the relevance of Carr's testimony, the court clarified that under MRE 401, evidence is relevant if it makes a consequential fact more or less probable. Carr's testimony directly pertained to self-defense, particularly whether the victim acted in a threatening manner by reaching for a gun upon instruction from another individual. The Court of Appeals had deemed this testimony irrelevant, suggesting that it did not affect the likelihood of the victim shooting at the defendant, and concluded that the defendant and Haus were initial aggressors, thereby negating the need for self-defense.

The current ruling disputes these findings, emphasizing that Carr's testimony was indeed relevant and had probative value regarding self-defense. The Court of Appeals’ erroneous conclusion about the aggressor status and potential for flight led to its mistake in deeming the testimony irrelevant. The court refrained from addressing the hearsay aspect raised by the Court of Appeals and instead reversed the decisions regarding the self-defense instruction and relevance of Carr’s testimony. The case is remanded to the Court of Appeals to evaluate if the trial court's erroneous denial of the self-defense instruction was harmless or outcome-determinative.

The Court of Appeals will evaluate the admissibility of Carr’s investigative-subpoena testimony under MRE 804(b)(1) and Clay’s statement to the victim as either an excited utterance under MRE 803(2) or non-hearsay under MRE 801(c). If deemed admissible, the Court will determine if the exclusion of Carr’s testimony was harmless or if it likely affected the trial's outcome, referencing Lukity, 460 Mich at 496. Although the defendant was charged with first-degree murder, he was acquitted by the jury. At sentencing, the trial court noted a minimum sentence guideline range of 225 to 375 months but imposed an upward departure, suggesting the defendant seemed guilty of first-degree murder, possibly indicating a jury compromise. If the Court affirms the conviction, it will re-evaluate the sentence according to People v Beck, 504 Mich. NW2d, 2019. The principle of due process prohibits sentencing a defendant for a crime after acquittal. The court does not retain jurisdiction and refrains from addressing the defendant’s claims of an unreasonable or disproportionate sentence pending the reconsideration in light of Beck.