Background
Terrill Chaney and accomplice Kendall Thornton were prosecuted for a 2011 home invasion and fatal shooting of Tamara Bates in Flint, Michigan. The investigation was reopened over a decade later as a cold case. At joint trial, the prosecution’s evidence included text messages from 2011 in which Chaney admitted breaking into Bates’s home to look for money and that his accomplice shot a woman; testimony from witness Jerod Blond that Chaney discussed the robbery and killing; and Thornton’s latent fingerprints recovered at the scene.
A jury convicted Chaney of felony-murder under MCL 750.316(1)(b), armed robbery, and first-degree home invasion, but acquitted him of felony-firearm charges. The trial court imposed a mandatory life-without-parole sentence for felony-murder, along with sentences of 285 months to 50 years for armed robbery and 140 months to 50 years for first-degree home invasion, applying a second-offense habitual offender enhancement.
The Court’s Holding
The court affirmed Chaney’s convictions on all counts, finding sufficient evidence of guilt. Text messages relayed Chaney’s contemporaneous admissions to breaking into the victim’s home with intent to steal; witness testimony corroborated his participation in the robbery; and Thornton’s fingerprints and forensic evidence supported the presence of both men at the scene. The court rejected arguments that the verdict was against the great weight of evidence, noting that witness credibility determinations belong to the jury.
The court also upheld the trial court’s evidentiary rulings, including admission of a 2017 police interview under the recorded recollection exception; text messages as present-sense impressions; and Facebook posts documenting witness intimidation. Although the court noted that certain jury instructions may have been technically incorrect or absent (such as a specific unanimity instruction), it found any defects harmless because convictions were supported by overwhelming evidence.
However, the court vacated Chaney’s felony-murder sentence. Because Chaney was 19 years old at the time of the crime, he is entitled to resentencing under *Miller v. Alabama*, which prohibits mandatory life-without-parole sentences for juveniles, and its extension by the Michigan Supreme Court in *People v. Taylor* (2025) to defendants aged 19 and 20. Resentencing must permit the trial court to consider mitigating factors related to youth.
Key Takeaways
- Convictions for armed robbery and first-degree home invasion are final; appellate courts defer to jury verdicts when evidence is viewed in the prosecution’s favor.
- *Miller* protections now extend to 19- and 20-year-old defendants in Michigan, not just juveniles under 18; youth sentencing hearings are mandatory for this cohort.
- Joint trials of co-defendants are strongly favored and permitted even when forensic evidence (e.g., fingerprints) directly implicates only one co-defendant, so long as defenses are not antagonistic and evidence is relevant to both.
- Trial counsel’s strategic decisions regarding jury instructions, witness selection, and trial structure receive substantial deference on appeal and are presumed sound absent clear deficiency and prejudice.
Why It Matters
This decision confirms Michigan’s commitment to *Miller* re-sentencing requirements for young adult offenders. Even defendants convicted of serious crimes and sentenced decades after commission may have their sentences vacated and re-imposed with youth-focused mitigation considerations. The ruling applies to a significant population of offenders and establishes that trial courts—not appellate courts—must weigh youth factors at sentencing.
The opinion also reinforces that appellate review of sufficiency of evidence and jury verdicts is highly deferential to trial outcomes. Convictions survive on relatively thin witness testimony and circumstantial evidence when corroborated by forensic evidence from a co-defendant. Additionally, the decision clarifies that trial counsel’s strategic choices receive broad presumptive validity, making ineffective-assistance claims difficult to sustain without concrete proof that a different strategy would have altered the verdict.