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S T A T E O F M I C H I G A N

C O U R T O F A P P E A L S

PEOPLE OF THE STATE OF MICHIGAN,

Plaintiff-Appellee,

UNPUBLISHED

February 15, 2018

v No. 334511

Oakland Circuit Court

TANIA CHRIS ALEXANDER, LC No. 2015-256549-FH

Defendant-Appellant.

Before: TALBOT, C.J., and METER and TUKEL, JJ.

PER CURIAM.

Tania Chris Alexander appeals as of right her jury trial convictions of fourth-degree 

fleeing and eluding1 and failure to stop at the scene of a property damage accident.

2

 Alexander

was sentenced to 180 days in jail for fleeing and eluding and 90 days in jail for failing to stop at 

the scene of a property damage accident. We affirm. 

On appeal, Alexander argues through counsel that her waiver of counsel in the lower 

court proceedings was not knowing, intelligent, and voluntary. Alexander also filed a Standard 4 

brief pursuant to Administrative Order 2004-6, Standard 4, arguing that her waiver was not 

knowing and voluntary, that she was denied assistance of counsel at the preliminary 

examination, that the prosecutor engaged in misconduct during closing argument, and that she 

received ineffective assistance of counsel when her advisory attorney did not object or counsel 

her regarding the prosecutor’s closing argument. We disagree. 

I. WAIVER OF COUNSEL

In order to preserve a challenge to the validity of a waiver of counsel, the defendant must 

properly raise the issue in the trial court.3 Alexander failed to raise this issue below. Thus, it is 

not preserved for appellate review and our review is limited to plain error affecting substantial 

 1 MCL 257.602a(2).

2 MCL 257.618.

3 People v Campbell, 316 Mich App 279, 283; 894 NW2d 72 (2016).
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rights.4 This Court generally reviews a trial court’s findings of fact regarding a defendant’s 

waiver of counsel for clear error; however, a determination regarding the meaning of “knowing 

and intelligent” is a question of law reviewed de novo.5

A defendant’s right to self-representation is provided by the Michigan Constitution, as 

well as by statute.6 The Sixth Amendment of the United States Constitution also implicitly 

guarantees the right to self-representation.7 However, several requirements must be met before a 

defendant may proceed in propria persona:

To invoke the right of self-representation: (1) a defendant must make an 

unequivocal request to represent himself, (2) the trial court must determine that 

the choice to proceed without counsel is knowing, intelligent, and voluntary, and 

(3) the trial court must “determine that the defendant’s acting as his own counsel 

will not disrupt, unduly inconvenience and burden the court and the 

administration of the court’s business.”

[8]

Whether a waiver is knowing and voluntary is a fact-intensive inquiry that requires review of the 

entire record.

9

 “A waiver is sufficient if the defendant knows what he is doing and his choice is 

made with eyes open.”10 Every reasonable presumption should be made against waiver.

11

The trial court must also substantially comply with MCR 6.005.12 MCR 6.005(D) 

provides that the court cannot accept a defendant’s initial waiver of the right to counsel without 

first

(1) advising the defendant of the charge, the maximum possible prison 

sentence for the offense, any mandatory minimum sentence required by law, and 

the risk involved in self-representation, and

 4 Id.

5 People v Williams, 470 Mich 634, 640; 683 NW2d 597 (2004).

6 People v Dunigan, 299 Mich App 579, 587; 831 NW2d 243 (2013), citing Const 1963, art 1, § 

13 and MCL 763.1.

7 Dunigan, 299 Mich App at 587.

8 Id., quoting People v Anderson, 398 Mich 361, 367-368; 247 NW2d 857 (1976).

9 Williams, 470 Mich at 640.

10 Campbell, 316 Mich App at 286 (quotation marks and citation omitted).

11 Williams, 470 Mich at 641.

12 People v Campbell, 316 Mich App at 284.
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(2) offering the defendant the opportunity to consult with a retained 

lawyer or, if the defendant is indigent, the opportunity to consult with an 

appointed lawyer.

Failure to substantially comply with these requirements renders a defendant’s waiver of counsel 

ineffective.13

A. DISTRICT COURT PROCEEDINGS

In the district court, Alexander was initially appointed Maxwell M. Manoogian as 

counsel. However, after being threatened with a grievance if he did not take actions Alexander 

deemed prudent, Manoogian moved to withdraw as Alexander’s counsel. Alexander had no 

objection to Manoogian’s withdrawal. After much discussion, the district court asked Alexander 

to clarify whether she wanted an appointed attorney. Alexander answered, “I have a right to not 

only just representation, I also have the right to assistance[.]” The district court asked Alexander

what she thought the difference was between representation and the type of assistance of counsel 

that she was requesting, and she said: “In my mind, an attorney representing me would be up 

here speaking on my behalf, as opposed to me speaking for myself. Assistance and advice of 

counsel would be me every move, every motion, my thoughts I would run through my 

counsel[.]” The district court agreed to have the circuit court appoint another attorney in an 

“advisory capacity[.]” After ensuring that Alexander was agreeable to adjourning the 

preliminary examination, the district court inquired as to why Alexander did not want someone 

who understood the court system and law to represent her. Alexander responded, “Because I feel 

like I speak up for myself . . . .” The court, again, asked,

The Court: And let me ask you one more time, you do not want an 

attorney to represent you; is that correct?

Tania Alexander: Correct. Just for--

The Court: You only want an attorney to consult with?

Tania Alexander: Yes, Your Honor.

The Court: All right. Has anybody promised you anything or threatened 

you to get you to waive your right to an attorney - -

Tania Alexander: No.

However, after the matter was adjourned, the district court learned that the circuit court 

was unwilling to appoint counsel “just to consult” at the preliminary examination. After 

recalling the case, the district court agreed to appoint advisory counsel as a courtesy in the

district court proceedings only, but explained that it could not do so with respect to the circuit 

 13 People v Russell, 471 Mich 182, 191-192; 684 NW2d 745 (2004).
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court proceedings. Alexander asserted that the district court was not acknowledging MCR 6.005, 

which she alleged provided her with the right to “assistance” of counsel. The court reiterated

that Alexander waived her right to counsel knowingly, voluntarily, and willingly, but still

appointed an attorney because Alexander kept “throwing this back as if everybody’s trying to 

deny you . . . an essential right to counsel.”

Another hearing was held in the district court on October 19, 2015, wherein Alexander’s 

second appointed attorney, Charles Farrar, moved to withdraw because Alexander once again 

declined a court-appointed attorney. In response to Farrar’s motion, Alexander stated that she 

was appearing “in propria persona and without the benefit of counsel,” and that she had no 

objection to Farrar’s request to withdraw. However, she again argued that she was entitled to the 

assistance and advice of counsel as a constitutional right, pursuant to MCR 6.005. The district 

court argued with Alexander to the point of warning that she would be held in contempt if she 

continued to interrupt. The court asked Alexander “bottom line” whether she wanted the court to 

allow Farrar to withdraw so she could represent herself:

The Court: . . . “[D]o you want counsel to represent you; this is a yes or a 

no?

Tania Alexander: I want the advice and assistance of counsel, Your 

Honor.

The Court: Do you want an attorney to represent you; that’s a yes or a no.

Tania Alexander: I’m very -- I’m --

The Court: If you -- if [you] say yes, then he is going to represent you. If 

you say no, then you’re declining court appointed counsel. I just need to know 

which one you want[.]

Tania Alexander: If that’s all the Court is willing to do, then no, Your 

Honor, I’m appearing in propria persona.

The district court also addressed several motions Alexander had filed, including a motion 

for a bill of particulars. With respect to that motion, the district court observed that Alexander 

made a number of arguments concerning capital crimes and concluded: “[T]hat’s the problem of 

going forward in pro per without assistance -- or without having an attorney represent you. This 

is not a capital case. . . . This is a felony. This is a fleeing and eluding; a two-year felony.” The 

district court then reviewed the felony information and, with respect to the second count—failing 

to stop at the scene of a property damage accident—said, “That was a 90-day misdemeanor[.]” 

After the court denied her motion, Alexander stated that she wanted a preliminary examination, 

which the court scheduled for a later date. 

At the outset of the preliminary examination, Alexander again announced her appearance 

as “in propria persona, without the benefit of counsel.” The district court stated: 
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[L]et me just make sure that this record is very clear. . . . Ms. Alexander has 

chosen not to have counsel appointed to her. We’ve been through that. The 

record is -- is replete with those discussions, so I will just leave that as -- as is.”

Alexander objected and said, “-- I did not waive --,” but the court cut her off, said that it was just 

making a record, and told her not to interrupt. Alexander represented herself throughout the 

preliminary examination, including cross-examination of Officer Peter Matejcik.

Alexander mistakenly argued that she had a right to standby counsel based on the Sixth 

Amendment and the “assistance of counsel” language included in MCR 6.005. “A defendant 

who asserts his right to self-representation has no absolute entitlement to standby counsel. As 

the Michigan Supreme Court explained in People v Dennany,

[14] ‘[A] defendant has a 

constitutional entitlement to represent himself or to be represented by counsel–but not both.’ ”15 

Two attorneys were appointed to represent Alexander, and both withdrew from representation 

when Alexander insisted that she wanted to represent herself. Although her responses to the 

court’s repeated inquiries as to whether she desired counsel were often equivocal on their face, 

she made it clear that she wanted to represent herself and did not want to be represented by 

counsel. Alexander informed the court that she preferred self-representation because she could 

“speak up for herself.” Even after the district court explained that many of her legal arguments 

were fundamentally flawed, Alexander continued to insist on self-representation. The district 

court also reviewed the charges with Alexander in connection with her motion for a bill of 

particulars, as well as the maximum penalty associated with the charges. Although it appears 

that the various altercations between the court and Alexander seemingly disrupted and burdened

the court, the district court allowed Alexander to proceed in propria persona, and the court was 

eventually able to dispose of Alexander’s motions, hold a preliminary examination, and bind the 

matter over to the circuit court for trial. The district court substantially complied with MCR 

6.005(D) and found that Alexander’s waiver was knowing and voluntary. In light of the above, 

the district court’s decision did not amount to plain error warranting relief.

In her Standard 4 brief, Alexander specifically argues that she was denied the right to 

“assistance of [c]ounsel and/or right to consult” during the preliminary examination. We 

disagree. Alexander relies on the prosecutor’s later remarks in the circuit court that he did not 

“know if there was a valid waiver of counsel” on the day of the preliminary examination, and his 

opinion that the waiver procedure was “inartfully done” by the district court judge. But as 

explained above, Alexander effectively waived her right to counsel in the district court prior to 

the preliminary examination. Moreover, when the prosecutor commented regarding the 

adequacy of Alexander’s waiver, the circuit court offered to remand the case to the district court 

so Alexander could be represented by counsel at a new preliminary examination. In response, 

Alexander continued to assert that she wanted to represent herself and said remand would have 

 14 People v Dennany, 445 Mich 412, 442; 519 NW2d 128 (1994). 

15 People v Kevorkian, 248 Mich App 373, 422; 639 NW2d 291 (2002) (first citation omitted).
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been “futile.” Alexander cannot decline remand for a preliminary examination with appointed 

counsel and then argue on appeal that she was deprived counsel at the preliminary examination.16 

Furthermore, even if Alexander had not effectively waived her right to counsel at the 

preliminary examination and had indeed been deprived of the right to counsel, the Michigan 

Supreme Court has recently held that the absence of counsel at a preliminary examination is 

subject to review for harmless error.17 On this record, we have no difficulty concluding that 

Alexander’s lack of counsel at the preliminary examination was harmless. Unlike the defendant 

in Lewis, Alexander was present for and participated in the entirety of the preliminary 

examination, and even cross-examined the prosecutor’s only witness. An advisory attorney was 

later appointed in the circuit court, and Alexander was free to consult with that attorney 

regarding impeaching Officer Matejcik at trial with his preliminary examination testimony. It is 

apparent that had Alexander been appointed counsel for the preliminary examination, she would 

have insisted that such counsel was advisory only and proceeded to represent herself. Indeed, 

she was adamant that she wanted to represent herself throughout the entirety of these 

proceedings. Thus, even if we found that Alexander did not sufficiently waive counsel for the 

preliminary examination and that she was denied the right to counsel at that critical stage, any 

resulting error was harmless.

B. CIRCUIT COURT PROCEEDINGS

In the circuit court, Alexander filed a motion “to appoint assistance of counsel in 

defendants [sic] criminal prosecution pursuant to the Sixth Amendment.” In her motion, she 

requested counsel for the “limited purpose” of consulting, and relied upon MCR 6.005(D). The 

court granted Alexander’s motion and appointed Melissa Sue Krauskopf as Alexander’s advisory 

counsel.

Alexander filed various motions thereafter, indicating that she was acting in propria 

persona “with the benefit of standby counsel,” including a motion to quash the bindover and 

dismiss the complaint. The circuit court held a hearing on this motion, where, once again, 

Alexander waived her right to counsel: 

The Court: Ms. Alexander, you understand that you have a right to -- an 

absolute right to an attorney to represent you in this matter?

Ms. Alexander: Yes.

The Court: We’ve been through this before and you’ve indicated you 

wish to waive your right to an attorney; is that correct?

 16 See People v McCray, 210 Mich App 9, 14; 533 NW2d 359 (1995) (“[A] party cannot request 

a certain action of the trial court and then argue on appeal that the action was error.”).

17 People v Lewis, 501 Mich 1, 9-10; 903 NW2d 816 (2017).
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Ms. Alexander: Yes.

The Court: And represent yourself?

Ms. Alexander: Yes.

The court had a similar interaction with Alexander at another hearing concerning several 

additional motions that Alexander filed in propria persona: 

The Court: Ms. Alexander. Do you understand my question? Do you 

want to represent yourself or do you want Ms. Krauskopf to be your attorney and 

file motions on your behalf? You have indicated on this record you are 

representing yourself because you are in pro per. That’s all I’m askin’.

[Alexander]: And I’ve indicated on the record your Honor that I can 

represent myself with the assistance of Counsel.

The Court: You’re representing yourself. Thank you, ma’am. . . .

At this hearing, as noted earlier, the prosecutor expressed doubt concerning whether Alexander 

had properly waived her right to counsel at the preliminary examination. However, when the 

court asked Alexander if she wanted a remand for the purpose of holding a new preliminary 

examination with the representation of counsel, she said remand to the district court with 

representation “would be wonderful except the fact that it would be futile.”

On the first day of trial, Alexander continued to assert that she desired to represent 

herself. The Court agreed that she was free to do so, but cautioned: “I expect that you’re going 

to deal in this case the same way every other lawyer does. I hold you to the same standard I hold 

Ms. Krauskopf [standby counsel] and [the prosecutor] to.” When the jury pool entered the 

courtroom, the court advised the prospective jurors that Alexander was representing herself with 

her “advisory counsel,” Krauskopf, and Alexander told the jury that Krauskopf was present for 

“assisting purposes, only.” Alexander was advised of her right to retain counsel or have counsel 

appointed before trial resumed on the second day, and Alexander wished to continue 

representing herself.

Based on the proceedings that took place prior to trial, it is clear that Alexander’s waiver 

of counsel in the circuit court was also sufficient. She filed a motion specifically asking for 

advisory counsel, which the circuit court granted. At every hearing prior to trial, she reiterated 

that she wanted to represent herself. At both days of trial, she again said she was appearing in 

propria persona and that Krauskopf was only present in an advisory manner. The circuit court 

reminded her of her right to counsel, chosen or appointed, before each session of trial. Thus, 

Alexander sufficiently waived her right to counsel, and the circuit court did not err by accepting 

her waiver. Although Alexander argues that her waiver was not unequivocal, for the reasons 

already explained, we disagree. Alexander consistently asserted her right to self-representation 

and insisted that she desired to proceed in propria persona, with the limited benefit of advisory 

counsel, which was in fact provided. Alexander is not entitled to appellate relief on this basis.
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II. PROSECUTORIAL MISCONDUCT

Next, Alexander argues in her Standard 4 brief that she was denied due process of law on 

the basis of statements made by the prosecutor during closing argument. We disagree.

A defendant must timely and specifically object to improper conduct by the prosecutor 

during trial, and request a curative instruction, to preserve a claim for prosecutorial misconduct.18 

Because Alexander failed to object to the remarks that serve as the basis for her claim of error, 

this issue is unpreserved, and this Court’s review is limited to plain error.

19 “To avoid forfeiture 

under the plain error rule, three requirements must be met[:] (1) an error must have occurred; (2) 

the error was plain; (3) and the plain error affected substantial rights, i.e., the defendant was 

prejudiced (the defendant generally must show that the error affected the outcome of the lower 

court proceedings).”

20 If the defendant can satisfy this standard, “[r]eversal is warranted only 

when the plain, forfeited error resulted in the conviction of an actually innocent defendant or 

when the error seriously affected the fairness, integrity, or public reputation of judicial 

proceedings.”

21

“Given that a prosecutor’s role and responsibility is to seek justice and not merely 

convict, the test for prosecutorial misconduct is whether a defendant was denied a fair and 

impartial trial.”

22 This Court reviews prosecutorial misconduct “on a case-by-case basis by 

examining the record and evaluating the remarks in context . . . .”

23 “The propriety of a 

prosecutor’s remarks depends on all the facts of the case.”24 The prosecutor’s comments must be 

read as a whole, and evaluated by this Court in light of the defendant’s arguments, and the 

relationship the comments bear to the admitted evidence.25 Prosecutors “are accorded great 

latitude regarding their arguments and conduct,” and they are “free to argue the evidence and all 

reasonable inferences from the evidence as it relates to [their] theory of the case.”

26 The 

prosecution “need not confine argument to the blandest possible terms.”27

 18 People v Bennett, 290 Mich App 465, 475; 802 NW2d 627 (2010).

19 People v Barber, 255 Mich App 288, 296; 659 NW2d 674 (2003).

20 Id.

21 Id.

22 People v Dobek, 274 Mich App 58, 63; 732 NW2d 546 (2007).

23 People v Mann, 288 Mich App 114, 119; 792 NW2d 53 (2010) (quotation marks and citation 

omitted).

24 People v Rodriguez, 251 Mich App 10, 30; 650 NW2d 96 (2002).

25 Id.

26 People v Bahoda, 448 Mich 261, 282; 531 NW2d 659 (1995) (quotation marks and citations 

omitted) (alteration in original).

27 Dobek, 274 Mich App at 66.
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During closing argument, the prosecutor told the jury that it could only consider the legal 

defenses included in the court’s instructions. He went on to explain that there was no defense of 

omission, mistake, necessity, or medical emergency for a charge of fleeing and eluding. The 

prosecutor noted that a legal defense justifies one’s actions, while an excuse merely explains 

those actions. He then argued that Alexander’s excuse for fleeing and eluding—that her mother 

was in medical distress—was “a hoax.” On appeal, Alexander contends that these statements 

misled the jury and conflicted with jury instructions. However, Alexander has failed to make

any effort to explain how the prosecutor’s closing argument was misleading or in conflict with 

the court’s jury instructions and, thus, has not demonstrated that the prosecutor’s closing 

argument constituted plain error. Importantly, Alexander emphasized in her opening statement 

that she was driving her ailing mother to the doctor at the time of the events giving rise to this

case and called a witness to testify regarding her mother’s health that morning. The prosecutor 

was simply presenting his theory of the case to the jury and responding to Alexander’s defense. 

Additionally, Alexander has not shown that her substantial rights were affected by the 

prosecutor’s closing argument. The prosecutor presented ample evidence establishing that 

Alexander was guilty of the charged offenses beyond a reasonable doubt. An individual is guilty 

of fourth-degree fleeing and eluding when: 

A driver of a motor vehicle who is given by hand, voice, emergency light, or siren 

a visual or audible signal by a police or conservation officer, acting in the lawful 

performance of his or her duty, directing the driver to bring his or her motor 

vehicle to a stop shall not willfully fail to obey that direction by increasing the 

speed of the motor vehicle, extinguishing the lights of the motor vehicle, or 

otherwise attempting to flee or elude the officer. This subsection does not apply 

unless the police or conservation officer giving the signal is in uniform and the 

officer’s vehicle is identified as an official police or department of natural 

resources vehicle.[28]

Three police officers testified regarding various instances in which Alexander willfully failed to 

comply with directives to pull over. Officer Matejcik signaled Alexander with his overhead 

lights, siren, public address system, and verbally. Alexander did not stop. Officers Aaron 

Sparks and Anthony Turner also signaled Alexander to stop with their lights and siren, to no 

avail. When Alexander finally pulled over—after having been boxed in by two police 

vehicles—she again attempted to accelerate, causing the officers to issue more verbal orders to 

stop. All three officers were dressed in uniform and riding in fully-marked police cars. 

The statute regarding failure to stop at the scene of a property damage accident provides 

that it is a misdemeanor if: 

The driver of a vehicle who knows or who has reason to believe that he has been 

involved in an accident upon public or private property that is open to travel by 

the public shall immediately stop his or her vehicle at the scene of the accident 

 28 MCL 257.602a(1).
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and shall remain there until the requirements of section 619[29] are fulfilled or 

immediately report the accident to the nearest or most convenient police agency 

or officer to fulfill the requirements of section 619(a) and (b) if there is a 

reasonable and honest belief that remaining at the scene will result in further 

harm. The stop shall be made without obstructing traffic more than is 

necessary.[30]

William McAlister, Jr., testified that Alexander continued driving after rear-ending his vehicle. 

The damage to his car was consistent with the collision he described. Alexander called 911 

twice, but did not report that she had been involved in an accident in either call. Rather, she just 

said that the police were following her and she was trying to get medical attention for her 

mother. In light of the overwhelming evidence of Alexander’s guilt, it is improbable that any 

allegedly improper remark by the prosecutor in closing argument affected the outcome of the 

proceedings.

III. INEFFECTIVE ASSISTANCE OF ADVISORY COUNSEL

Lastly, Alexander argues in her Standard 4 Brief that she was denied the effective 

assistance of counsel when her advisory trial counsel failed to instruct her to object to the 

prosecutor’s closing argument. We disagree.

“When a defendant did not move in the trial court for a new trial or an evidentiary 

hearing, this Court’s review is limited to mistakes apparent from the record.”

31 Claims of 

ineffective assistance of counsel are mixed questions of law and fact.32 “A judge must first find 

the facts, then must decide whether those facts establish a violation of the defendant’s 

 29 MCL 257.619 requires an individual who knows or has reason to believe that he or she was 

involved in an accident to: 

(a) Give his or her name and address, and the registration number of the 

vehicle he or she is operating, including the name and address of the owner, to a 

police officer, the individual struck, or the driver or occupants of the vehicle with 

which he or she has collided.

(b) Exhibit his or her operator’s or chauffeur’s license to a police officer, 

individual struck, or the driver or occupants of the vehicle with which he or she 

has collided.

(c) Render to any individual injured in the accident reasonable assistance 

in securing medical aid or arrange for or provide transportation to any injured 

individual. [MCL 257.619.] 

30 MCL 257.618(1) (citation omitted).

31 People v Heft, 299 Mich App 69, 80; 829 NW2d 266 (2012).

32 People v Armstrong, 490 Mich 281, 289; 806 NW2d 676 (2011).
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constitutional right to the effective assistance of counsel.”33 This Court reviews the trial court’s 

findings of fact for clear error, and reviews questions of constitutional law de novo.

34 “Clear 

error exists if the reviewing court is left with a definite and firm conviction that the trial court 

made a mistake.”35

To establish ineffective assistance of counsel, a defendant must show: “(1) counsel’s 

performance was below an objective standard of reasonableness under prevailing professional 

norms and (2) there is a reasonable probability that, but for counsel’s error, the result of the 

proceedings would have been different. . . . A defendant must also show that the result that did 

occur was fundamentally unfair or unreliable.”36 Effective assistance of counsel is “strongly 

presumed.”

37 A defendant claiming to have been denied the effective assistance of counsel must 

establish the factual predicate of his or her claim.38

Alexander appeared at trial in propria persona, after repeated arguments with the court 

regarding her request for the “assistance” of counsel or counsel to “consult with.” However, “[a] 

defendant who asserts [the] right to self-representation has no absolute entitlement to standby 

counsel.”39 Like Alexander, the defendant in People v Kevorkian, claimed that his standby 

counsel did too little.40 In rejecting the defendant’s claim of error in Kevorkian, this Court 

reasoned: “[A] defendant who chooses to represent himself does so at his own peril. With no 

constitutional right to [standby counsel], a defendant proceeding in propria persona has no basis 

to claim that [standby counsel] must abide by constitutional standards,” and “ ‘generally cannot 

prove standby counsel was ineffective.’ ”

41 The defendant in Kevorkian represented himself 

with standby counsel “in reality as well as in name.”

42 Because the defendant represented 

himself, he could not blame his standby counsel for his conviction.43 Standby counsel was not 

acting as counsel within the meaning of the Sixth Amendment and, therefore, could not be held 

to the standards of effective assistance required of trial attorneys.44 Moreover, this Court found 

that the standby counsel’s performance did not fall below an objective standard of 

 33 Id. (quotation marks and citation omitted).

34 Id.

35 Id.

36 People v Lockett, 295 Mich App 165, 187; 814 NW2d 295 (2012).

37 People v Vaughn, 491 Mich 642, 670; 821 NW2d 288 (2012).

38 People v Douglas, 496 Mich 557, 592; 852 NW2d 587 (2014).

39 Kevorkian, 248 Mich App at 422.

40 Id. at 424.

41 Id. at 424-425 (citation omitted).

42 Id. at 426.

43 Id.

44 Id. at 427.
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reasonableness, and the defendant did not show that but for the standby counsel’s alleged errors, 

the result of the proceedings would have been different.45

The same holds true in this case. Krauskopf was not acting within the meaning of the 

Sixth Amendment when she appeared as advisory counsel to Alexander at trial. Thus, she is not 

held to the same standard of effective assistance of counsel that is required for trial attorneys.46 

In any event, Alexander’s argument also lacks merit because, even if Krauskopf had been 

representing Alexander in the traditional sense, failure to make a meritless objection does not 

constitute ineffective assistance of counsel.

47

Affirmed.

/s/ Michael J. Talbot

/s/ Patrick M. Meter

/s/ Jonathan Tukel

 45 Id.

46 Id. at 426-427.

47 People v Pinkney, 316 Mich App 450, 473; 891 NW2d 891 (2016).