Appeal denied in 2017 Niles homicide
Published 8:41 am Tuesday, November 19, 2019
NILES — James Parker Huffman has had his appeal denied from his 2018 murder conviction. A three-judge panel of the Michigan Court of Appeals last week affirmed Huffman’s conviction for the 2017 murder of his longtime girlfriend, Angela Cluver.
The Cluver murder was one of two Niles area murders in the summer of 2017.
The Cluver murder occurred July 21, 2017, in what Huffman claimed was a failed murder-suicide pact at the couple’s S. 14th Street home in the city of Niles. A few weeks later, Carla Lewis was found dead inside her Niles Township home on Lawndale Avenue and her husband, John, was later convicted of her murder.
Huffman, 54, of S. 14th Street in Niles, was sentenced in April 2018 to a mandatory term of life in prison without the chance for parole. He was found guilty earlier that year by a Berrien County Trial Court jury of killing Angela Cluver at their Niles home.
Huffman walked into the Niles Law Enforcement Complex three days later, on July 24, 2017, and told police that he had strangled Cluver in a failed double suicide pact. Police then went to the home and discovered Cluver’s body, which was in a state of decomposition. He claimed he tried but failed to kill himself.
Huffman’s suicide claim was dismissed by Berrien County Trial Judge Charles LaSata at Huffman’s April 2018 sentencing. LaSata called him “callous” and a “cold, calculated killer.” The judge noted that he had gotten worse scratches picking raspberries than Huffman had on his arms from trying to kill himself.
The initial case, as well as the appeal, raised issues related to suicide and euthanasia.
In his appeal, Huffman claimed that his attorney was not allowed to question witnesses about the victim’s alleged suicidal state of mind and financial difficulties. The appeal conceded that the victim’s consent is not a defense for first-degree murder, but his attorney stated that the consent question was relevant to show that it was not pre-meditated.
“However, defendant’s argument fails to make a logical connection to the proffered evidence of the victim’s intent to commit suicide and defendant’s premediated intent to kill without running afoul of Kevorkian’s prohibition of consent and euthanasia as a defense,” the Court of Appeals ruling stated.
“Defendant declares that the victim’s suicidal mindset was relevant to show when precisely defendant solidified his intent to kill the victim. However, although evidence of a motive is generally admissible … the proffered motive by defendant in this case is expressly prohibited as a defense. There is simply no relevancy to defendant’s proffered evidence of the victim’s state of mind and intent to commit suicide.”
Huffman also appealed another trial court decision to exclude evidence that he said would show Cluver’s intent to commit suicide. The Court of Appeals panel disagreed, noting that the testimony exclusion did not prejudice him or warrant a mistrial being called and the testimony could in fact infer premeditation.
The final issue raised in his appeal was that the evidence was not sufficient for conviction and that the prosecution did not present evident showing that Huffman premeditated the homicide.
“Defendant is wrong,” the Court of Appeals noted.
“This testimony tends to show that defendant’s act of killing was reasoned and thought out for some time before the act. Moreover, defendant admitted that his act of strangulation occurred for roughly five minutes. Our Supreme Court has previously recognized that manual strangulation on its own may be sufficient evidence of premeditation for first-degree
premeditated murder.
“In light of defendant’s admission that the strangulation of the victim occurred for five minutes, there is sufficient evidence of defendant’s premeditated intent to kill the victim even if a suicide pact existed,” the ruling concluded. “Additionally, the forensic pathologist explained that the victim suffered abrasions on the front of the neck and injuries in the mouth and gum line. He opined that these injuries occurred before the victim’s death. The evidence was sufficient to support defendant’s conviction.”