Background
Hunter William Locke-Hughes, then nineteen, was dating Ashlynn Bethell, a mother of two. Her elder child, six-year-old Terrance, was severely disabled with CHARGE syndrome — a genetic disorder that left him nonverbal, visually and hearing impaired, reliant on a feeding tube, and prone to aspiration, self-harming behavior, and respiratory illness. Children’s Protective Services had been actively involved with the family for months prior to Terrance’s death, and a safety plan was in place that directed Bethell not to leave Terrance alone with Locke-Hughes due to his lack of special-needs training. That plan was violated on the evening of December 28, 2021, when Bethell’s usual babysitter cancelled and Locke-Hughes — who had never supervised the children for a full work shift — offered to watch them while she worked her night shift at Domino’s Pizza.
Within roughly thirty minutes of Bethell’s departure, Locke-Hughes made a series of increasingly frantic calls to her: first reporting that Terrance had vomited, then that he had defecated in the bathtub, and finally that the child was not breathing. Emergency responders found Terrance unresponsive on the bedroom floor in asystole, with contusions on his forehead, a clenched jaw (which paramedics found atypically consistent with early rigor mortis), fluid coming from his mouth, ears, and nose, and feces in and around the bathtub. He was transported to the hospital and pronounced dead shortly after arrival. The Macomb County Medical Examiner performed an autopsy, identified the cause of death as drowning, and listed the manner of death as indeterminate.
Locke-Hughes was interviewed twice by Clinton Township detectives. In a first, non-custodial interview the night of Terrance’s death, he said Terrance had re-entered the bathtub on his own and drowned. In a second interview on April 6, 2022 — conducted after detectives received the autopsy report and without Miranda warnings being given — Locke-Hughes made statements acknowledging that he held Terrance’s body down in the water by his shoulders for up to thirty to forty-five seconds to wash him, while continuing to deny that he ever submerged Terrance’s head. He also agreed, in response to leading questions, that it was “possible” he had lost awareness of what he was doing, and that whatever occurred was accidental. The trial court denied a pre-trial motion to suppress those statements, finding the April 6 interview was not custodial. Locke-Hughes was tried before a jury in January 2024 and convicted of first-degree child abuse and the lesser-included offense of involuntary manslaughter. He was sentenced to 90 months to 30 years and 43 months to 15 years, concurrently, with the trial judge departing downward 45 months from the recommended guideline minimum on the child abuse count.
The Court’s Holding
The Michigan Court of Appeals vacated both convictions and remanded the case for a new trial. On appeal, Locke-Hughes argued that the evidence was insufficient to support the first-degree child abuse conviction, that his trial counsel was constitutionally ineffective, and that he was denied the right to a fair trial. The prosecution filed a cross-appeal challenging the downward sentencing departure. The court’s decision to vacate on at least one of those defense grounds rendered the prosecution’s cross-appeal moot.
A significant portion of the court’s opinion focused on the April 6, 2022 custodial interrogation issue. The panel conducted its own review of the interview video and found the exchange “more nuanced, and ultimately more incriminating” than the detective’s trial testimony had conveyed. The officers conducted that second interview primarily through leading questions, repeatedly suggested their own narrative of events, invoked themes of God, redemption, and forgiveness, and retained Locke-Hughes’ cell phone contrary to their stated intention of returning it — all without advising him of his Miranda rights. The trial court’s analysis had applied the totality-of-circumstances factors from People v. Barritt, 325 Mich App 556 (2018), but the appeals court’s close reading of the record indicated the lower court’s characterization of the interview as non-custodial was open to significant challenge.
The court’s analysis of the additional grounds — sufficiency of evidence, ineffective assistance, and fair trial — is contained in portions of the opinion not reproduced in the available text, but the ultimate disposition — vacatur of all convictions and remand for a new trial — is stated unequivocally in the opening paragraph of the per curiam opinion authored by Judges Young, Borrello, and Trebilcock.
Key Takeaways
- An interview conducted at a police station, without Miranda warnings, where officers use leading questions, withhold a suspect’s property contrary to prior representations, and employ religious and emotional pressure may cross the line into custodial interrogation — even when the suspect arrived voluntarily and was told the interview would be brief.
- Appellate courts will independently review interview recordings and are not bound by a trial court’s characterization of an interrogation’s tone or content; the panel here expressly noted the video revealed a more incriminating exchange than the detective’s testimony described.
- A downward departure from sentencing guidelines, even one supported by findings of accepted responsibility and lack of criminal history, may be challenged by the prosecution on cross-appeal — though such a challenge becomes moot if convictions are vacated.
- The unpublished status of this opinion means it has no binding precedential effect under Michigan Court Rules, but it illustrates the weight courts will place on the totality-of-circumstances inquiry in close custodial-interrogation cases.
Why It Matters
This case highlights the constitutional risks that arise when law enforcement, having pivoted from a non-custodial information-gathering session to a targeted interrogation, fails to administer Miranda warnings before pressing a suspect with leading questions, psychological appeals, and suggestion-laden hypotheticals. The defendant here made no unambiguous confession, yet the statements obtained in the second interview were central to the prosecution’s case. The appeals court’s willingness to independently scrutinize the interview video — and to characterize it differently than the trial court did — signals that Michigan appellate panels will look hard at the substance of interrogation recordings, not merely at facially neutral factors like room size or the absence of physical restraint.
For practitioners, the case is also a reminder of the compounding risks in prosecutions involving disabled child victims: when the medical evidence is equivocal (indeterminate manner of death, competing expert interpretations of injuries) and the defendant’s statements are ambiguous, admission or exclusion of interrogation evidence can be outcome-determinative. A new trial without the April 6 statements — if that is the ground for vacatur — would present prosecutors with a substantially harder evidentiary path to conviction.