Background
Jaelen Dashaun Matthews arranged to meet a man who sold THC edibles at a Detroit gas station after concealing his identity and calling from an unfamiliar number. Matthews entered the man’s vehicle, where a struggle and gunfire followed. The man escaped from the vehicle but was shot several times by Matthews’s codefendant, Ronald Johnson, leaving him permanently paralyzed. Evidence also indicated that Matthews restrained or wrestled with the victim and kicked him after he fell.
Separate juries considered the charges against Matthews and Johnson during their joint trial. Johnson’s jury heard his statement that he shot the armed victim in defense of Matthews and acquitted Johnson. Matthews’s jury did not hear that hearsay statement but was instructed on self-defense and aiding and abetting. It convicted Matthews of assault with intent to commit great bodily harm less than murder and the associated felony-firearm offense. Matthews appealed, arguing that Johnson’s acquittal meant no underlying crime existed for him to aid and abet and that the differing verdicts reflected jury confusion.
The Court’s Holding
The Michigan Court of Appeals affirmed, holding that Matthews’s jury received sufficient evidence to find that Johnson committed an unjustified assault, regardless of Johnson’s acquittal by a different jury. A principal’s conviction is not required to convict an aider and abettor, and inconsistent verdicts are permissible. Because the two juries heard different evidence, Matthews’s jury could rationally reject self-defense and find that an underlying crime occurred.
The court also held that the evidence supported the remaining elements of aiding and abetting. Matthews concealed his identity to arrange the meeting, brought armed backup, tried to prevent the victim from fleeing, wrestled with him, and kicked him while he was down. Those circumstances permitted findings that Matthews assisted the assault and that he intended it, knew of Johnson’s intent, or knew that assault with intent to cause great bodily harm was a natural and probable consequence of the confrontation he initiated.
Finally, the court rejected Matthews’s unpreserved instructional-error claim under plain-error review. The instructions accurately required the prosecution to prove that Matthews or another person committed the crime, that Matthews assisted before or during its commission, and that he possessed the required intent or knowledge. Nothing in the record established jury confusion, misunderstanding, or an impermissible compromise.
Key Takeaways
- An aider and abettor may be convicted even when the alleged principal is acquitted, provided the defendant’s jury rationally finds that the underlying crime occurred.
- Different juries in a joint trial may reach inconsistent verdicts, particularly when evidentiary rules cause them to hear different evidence.
- Arranging a concealed-identity confrontation, bringing armed backup, restraining the victim, and participating in the assault supplied sufficient circumstantial evidence of assistance and intent.
Why It Matters
The decision illustrates that an alleged principal’s acquittal does not automatically defeat accomplice liability in Michigan. Each verdict is assessed from the evidence presented to that particular jury, and facial inconsistency alone does not establish reversible error.
For defendants challenging inconsistent verdicts, the opinion underscores the need to identify concrete evidence of jury confusion, misunderstood instructions, or impermissible compromise. It also shows the importance of preserving instructional objections at trial, because an unpreserved challenge must satisfy the demanding plain-error standard.