Michigan v. Rajput (Opinion on Application)Annotate this Case
Nadeem Rajput was convicted of second-degree murder. Defendant was driving his vehicle with another man, known only as Haus, as a passenger. The victim was driving a red Malibu with her boyfriend, Dewayne Clay, as a passenger. When the Malibu approached defendant’s vehicle, two individuals in the Malibu fired gunshots at defendant and Haus. No one was injured. Defendant and Haus returned to defendant’s house but soon after went in search of the Malibu. When they found the Malibu, the victim was the sole occupant. Defendant and Haus chased the Malibu, eventually trapping it, and then approached the Malibu on foot. An argument ensued, and multiple gunshots were fired, resulting in the victim’s death. Defendant was charged with first-degree premeditated murder, and possession of a firearm during the commission of a felony. Defendant argued that Haus had shot the victim but that Haus had done so in self-defense when the victim reached for a gun in her vehicle. Defendant requested that a self-defense instruction be read to the jury, but the court denied the request, citing Michigan v Droste, 160 Mich 66 (1910), for the proposition that a defendant who claims that another person committed the homicide was not entitled to a self-defense instruction. Defendant also tried to admit testimony to support his self-defense theory. The trial court refused to admit the testimony, finding it irrelevant. The jury acquitted defendant of first-degree murder and felony-firearm but convicted defendant of second-degree murder. At sentencing, the court noted defendant’s guidelines minimum sentence range of 225 to 375 months’ imprisonment but departed upward, sentencing defendant to 46 to 95 years’ imprisonment. Defendant appealed. The Court of Appeals affirmed the trial court’s rulings on the self-defense instruction and the proffered testimony. Although it disagreed with the trial court’s reasoning, the appellate court held that defendant was not entitled to a self-defense instruction because he and Haus were the initial aggressors and could have fled. The Court of Appeals also held the proffered testimony was irrelevant. The Michigan Supreme Court reversed the Court of Appeals’ holding that defendant was not entitled to his requested self-defense instruction and that the testimony was irrelevant, “If supported by the evidence, defendant’s theory of the case must be given.” The matter was remanded for further proceedings.