People of Michigan v. Michael Degraffenried

── People of Michigan v. Michael Degraffenried ── Court: Michigan Court of Appeals Date: June 05, 2026 Category: General 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 STATE OF MICHIGAN COURT OF APPEALS PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 05, 2026 Plaintiff-Appellant, 1:25 PM v No. 377440 Wayne Circuit Court MICHAEL DEGRAFFENRIED, LC No. 99-006691-01-FC Defendant-Appellee. Before: YOUNG, P.J., and BORRELLO and TREBILCOCK, JJ. PER CURIAM. The prosecution appeals by leave granted1 the trial court’s order granting relief from judgment in favor of defendant, Michael Degraffenried. Because the trial court did not apply the correct legal framework, and because the trial court’s decision contained numerous factual and legal errors, we vacate the trial court’s order and remand for further proceedings.2 1 People v Degraffenried, unpublished order of the Court of Appeals, entered October 22, 2025 (Docket No. 377440). 2 This is the second time in this case—and one of many occasions the past two calendar years— where this Court has sent a motion for relief for judgment back to this trial court for proper legal analysis or factual development. See People v Degraffenried, unpublished order of the Court of Appeals, entered December 22, 2021 (Docket No. 358624); People v Crane, unpublished order of the Court of Appeals, entered June 6, 2025 (Docket No. 375857); People v Pittman, unpublished order of the Court of Appeals, entered May 3, 2024 (Docket No. 369182); People v Onumonu, unpublished per curiam opinion of the Court of Appeals, issued March 21, 2024 (Docket No. 363065). A complete factual record and close adherence to the court rules are critical to avoid substantial costs in terms of both labor and time to this Court, but more importantly to the individuals involved in these cases. -1-  I. FACTS On June 15, 1999, a drive-by shooting occurred outside a house on Florence Street in Inkster, Michigan. At the time, there was an ongoing conflict between two neighborhood groups. Alondrae Davis was killed, while Larry Abullah, Willie Wimberly, and Raymone Williams were reportedly wounded. Degraffenried and his girlfriend, Tiya Manning, were arrested and charged with first- degree premeditated murder, MCL 750.316(a); two counts of assault with intent to commit murder, MCL 750.83; and felony-firearm, MCL 750.227b. At their preliminary examination, Manning’s statement to police, in which she implicated Degraffenried and Williams as the shooters, was read into the record. Before trial, a Walker3 hearing was held to determine the voluntariness of Manning’s statement. The trial court suppressed her statement, and Manning’s trial was severed from Degraffenried’s. See People v Manning, 243 Mich App 615, 618-620; 624 NW2d 746 (2000). At Degraffenried’s trial in 2000, Broderick Ward and Abullah identified Degraffenried as the shooter. Degraffenried presented an alibi, insisting he was with his grandmother at the Inkster Police Department picking up his 16-year-old cousin. Multiple witnesses who had implicated Degraffenried as the shooter testified at trial that officers from the Inkster Police Department, including Detective Darian Williams, Detective Anthony Abdallah, and Detective Gregory Hill, threatened and coerced them into identifying Degraffenried. No physical evidence connected Degraffenried to the shooting. Degraffenried was convicted of second-degree murder, MCL 750.317; two counts of assault with intent to