Background
In the early morning hours of March 29, 2022, St. Clair County sheriff’s deputies responded to a 911 call reporting a home invasion with shots fired at Gregory Ringel’s residence. Ringel initially told officers he had been awakened by a gunshot, armed himself with a pistol, and fired at a shadowy intruder who fled through the garage. His wife, DR, told a different story: she was awakened by a noise, and as she opened her bedroom door, someone fired a shotgun at her — close enough to cause a powder-burn rash from her ear to her collarbone. She struggled to close the door against the shooter, who jammed the shotgun barrel into the doorframe before withdrawing.
Law enforcement found no evidence of an intruder. A search of Ringel’s phone revealed he was having an affair with a coworker. Confronted by detectives, Ringel admitted he fired the shotgun, then described an elaborate cover-up: he hid the shotgun behind a garage cabinet, fired his pistol into a bathroom wall to simulate an intruder exchange, and made the false 911 call. He claimed he had been in a “fog” during the shooting and only regained clarity afterward. At trial, Ringel testified that he had been experiencing a steroid-induced psychotic episode and believed he was hunting pheasants with his deceased father when he fired the shot.
A psychiatry expert, Dr. Gerald Shiener, testified on Ringel’s behalf that an aggressive corticosteroid prescription begun in February 2022 could have caused psychosis, potentially explaining perceptual distortions. The jury nevertheless convicted Ringel of assault with intent to murder, discharge of a firearm in or at a building, two counts of felony-firearm, false report of a felony, and tampering with evidence. The St. Clair Circuit Court sentenced him to 15 to 30 years’ imprisonment on the assault with intent to murder conviction, a term at the middle of the applicable guidelines range of 135 to 225 months.
The Court’s Holding
The Michigan Court of Appeals affirmed on all issues. On sufficiency of the evidence, the court held that the jury had more than adequate circumstantial evidence from which to infer intent to kill: Ringel retrieved a shotgun kept separately from his locked gun safe, loaded it with a buckshot round stored in his dresser drawer, walked to DR’s room, fired toward center mass as she opened the door, and then continued to advance and jam the barrel into the doorframe. The court further held that Ringel’s immediate and extensive cover-up — hiding the shotgun, staging a second shot, and fabricating an intruder story repeated to law enforcement, his wife, and friends — independently supported the intent inference. The court deferred to the jury’s credibility determination rejecting the psychotic-episode defense, noting that Ringel appeared coherent to officers immediately after the shooting and had never reported medication side effects to his doctors or anyone close to him.
On the OV 6 sentencing-variable challenge (50 points scored for premeditated intent to kill), the court held that Ringel had waived the issue rather than merely forfeiting it. At sentencing, when asked whether the presentence investigation report was factually accurate, defense counsel stated Ringel was “not challenging the accuracy of the report.” That express statement of satisfaction constituted an intentional relinquishment of the scoring objection under People v. Kowalski, 489 Mich 488 (2011), foreclosing appellate review entirely.
On proportionality, the court held that Ringel’s within-guidelines sentence carried a rebuttable presumption of proportionality under People v. Posey, 512 Mich 317 (2023), and that he failed to present the unusual circumstances required to overcome it. The court rejected the argument that the trial court ignored mitigating factors — including Ringel’s military service and PTSD diagnosis — noting that the PSIR contained that information, defense counsel highlighted it at sentencing, and the low prior-record-variable score already incorporated his lack of criminal history.
Key Takeaways
- Minimal circumstantial evidence suffices to prove intent to kill under Michigan law; a defendant’s use of a deadly weapon, targeting of a victim, and post-offense concealment conduct can each independently support the inference, even without an explicit statement of murderous purpose.
- A defendant who affirmatively tells the trial court that the presentence investigation report — including the scored sentencing guidelines — is accurate waives, not merely forfeits, any scoring challenge on appeal, eliminating even plain-error review.
- A within-guidelines sentence is presumptively proportionate in Michigan after Posey; military service, mental health history, and a clean prior record do not constitute the “unusual circumstances” required to rebut that presumption where those factors were before the court and are already reflected in the guidelines calculation.
- A psychotic-episode defense faces a steep credibility hurdle when the defendant appeared coherent to first responders immediately after the offense, engaged in a sophisticated multi-step cover-up, and never contemporaneously reported the alleged medication side effects.
Why It Matters
The decision is a practical reminder to defense counsel in Michigan that approving the accuracy of a presentence investigation report — often done reflexively to streamline sentencing — can permanently foreclose guideline-scoring arguments on appeal. The distinction between waiver (intentional relinquishment) and forfeiture (failure to object) is outcome-determinative: forfeiture allows plain-error review, waiver does not. Counsel who anticipate challenging OV scores must raise those objections explicitly at sentencing rather than waiting for appeal.
The case also illustrates the limits of an involuntary-act or psychosis defense when the defendant’s post-offense behavior tells a different story. Courts and juries are likely to scrutinize claims of unconscious or delusional conduct skeptically where the defendant engaged in calculated, multi-step evidence destruction immediately after the alleged episode — conduct that itself reflects purposeful, goal-directed thinking.