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Maples v. State

Court of Appeals of Michigan

May 14, 2019

DAVID A. MAPLES, Plaintiff-Appellant,
STATE OF MICHIGAN, Defendant-Appellee.

          Court of Claims LC No. 17-000135-MZ

          Before: Swartzle, P.J., and Cavanagh and Cameron, JJ.

          Cameron, J.

         Plaintiff, David A. Maples, filed this lawsuit for compensation under the Wrongful Imprisonment Compensation Act (WICA), MCL 691.1751 et seq., after his plea-based conviction for delivery of cocaine was reversed on appeal and the trial court dismissed the criminal charges. Maples now appeals the Court of Claims's order granting summary disposition[1] in favor of defendant, the State of Michigan, because Maples failed to show "new evidence" that satisfied the requirements under MCL 691.1755(1)(c). Finding no error in the Court of Claims's decision, we affirm.


         In August 1993, Maples, Lawrence Roberts, and James Murphy were arrested and charged with delivery of cocaine and conspiracy to deliver cocaine. The charges arose from a drug transaction that occurred when Maples and Roberts met Murphy at a bar. While at the bar, apparently unbeknownst to Maples and Roberts, Murphy sold cocaine to an undercover police officer. When Maples and Roberts left the bar together, they were pulled over and arrested. The charges against Roberts were eventually dismissed.

         Shortly after his arrest, Murphy wrote a letter to the trial court, explaining that Maples and Roberts had nothing to do with the cocaine sale. Murphy reiterated Maples's innocence during a February 1994 hearing on Murphy's entrapment motion, which Maples joined. During the hearing, Murphy testified that Maples was neither involved in nor aware of the cocaine sale.

         Maples was not scheduled for trial until September 1995. Unsuccessful in his attempt to have his case dismissed for entrapment and on a speedy trial violation, Maples expressed his intent to call Murphy as a defense witness in Maples's trial. However, on the eve of trial, Maples learned that Murphy had accepted a plea offer from the prosecution that awarded him a reduced sentence in exchange for agreeing not to testify on Maples's behalf. Further, Maples's only other witness, Roberts, could not be located for trial. Maples then pleaded guilty to delivery of cocaine because he did not have any exculpatory witnesses available and his attorney assured him that he could still appeal the speedy trial issue. After Maples was sentenced to 10 to 20 years' imprisonment, Murphy executed affidavits in 1997 and 2007 in which he attested that Maples was never involved in the crimes alleged. Murphy's affidavits were consistent with his testimony from the February 1994 entrapment hearing.

         Thereafter, Maples attempted to appeal the denial of his motion to dismiss for a speedy trial violation. A panel of this Court found that Maples had waived review of his claims when he pleaded guilty.[2] The Michigan Supreme Court denied leave to appeal. People v Maples, 459 Mich. 867; 584 N.W.2d 738 (1998).

         Maples then filed a petition for habeas corpus in the federal district court, raising issues of ineffective assistance of counsel and the denial of his right to a speedy trial. Maples v Stegall (Maples I), 340 F.3d 433, 434, 436 (2003). The district court denied his petition, but it did not explicitly rule on Maples's ineffective assistance of counsel claim. Id. at 436. On appeal, the Sixth Circuit Court of Appeals held that trial counsel's performance was constitutionally deficient because counsel's advice to Maples-that he could pursue a speedy trial claim at the appellate level despite the unconditional guilty plea-was "patently erroneous." Id. at 439. However, the Sixth Circuit remanded the case back to the district court to analyze Maples's likelihood of success on his speedy trial violation claim in order to determine if there was the requisite prejudice to substantiate an ineffective assistance of counsel claim. Id. at 440-441.

         On remand, the district court concluded that Maples's speedy trial claim had no merit, and thus, he could not succeed on his ineffective assistance of counsel claim. See Maples v Stegall (Maples II), 427 F.3d 1020, 1023 (2005) (discussing the district court's holding). However, the Sixth Circuit concluded, inter alia, that although evidence that Roberts would have provided beneficial testimony was weak, evidence to the contrary was weaker, and had Roberts been available for trial, he would have testified on Maples's behalf. Id. at 1032-1033. Thus, because Roberts could no longer be located by the time of trial, Maples was prejudiced by the delay. Id. at 1033. The court also determined that Murphy's unavailability to testify because of his plea agreement prejudiced Maples. Id. at 1034. The court noted that Murphy had given testimony that favored Maples at the entrapment hearing in February 1994. Id. Because both Roberts and Murphy would have testified favorably for Maples, but both were unavailable by the time of trial, the Maples II court concluded that Maples suffered actual prejudice from the delay. Id. Thus, the Sixth Circuit held that Maples's speedy trial violation claim had merit, which meant that he suffered a violation of his right to the effective assistance of counsel. Id. Accordingly, the Maples II court reversed the district court's decision and remanded the case with directions to issue a writ of habeas corpus. Id.

         After the district court's issuance of the writ of habeas corpus, the state criminal court dismissed Maples's criminal charges and vacated his conviction in 2006. Approximately 11 years later, Maples filed his WICA complaint in the Court of Claims.

         Maples maintained that he met the WICA requirements for compensation. Specifically, he claimed that "new evidence," in the form of Murphy's testimony, affidavits, and letter, as well as Roberts's proposed testimony, demonstrated Maples's innocence and had resulted in the reversal of his conviction and dismissal of his charges. The Court of Claims noted that the WICA defined "new evidence" to include evidence that was not presented at "the proceedings leading to the plaintiff's conviction," that Maples had joined in Murphy's entrapment motion, and that Murphy had testified at the entrapment hearing that Maples had no knowledge of the cocaine sale and did not participate in it. Concluding that the entrapment hearing was a pretrial hearing that led to Maples's conviction and that Murphy's testimony at the entrapment hearing was the same evidence that Maples was now attempting to use to support his WICA claim, the Court of Claims determined that by definition, it was not "new ...

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