People v. Hommerson 

Defendant was convicted of first-degree murder of wealthy couple after having fled to Mexico for ten years. Testimony elicited from his wife did not violate marital privilege, because wife was acting as Defendant's agent when, solely for his benefit, she followed his directions to lie about his activities on day of murders, register at motel under fictitious name, and borrow a car to drive to Mexico, thus was exception to marital privilege. Defense counsel's decision to present testimony of wife that Defendant told her he thought police were trying to pin crime on him, and that he was not guilty, was trial strategy, as a way to help establish his theory of case, not ineffective assistance of counsel. Few improper remarks in prosecutor's closing argument do not rise to level of reversible error nor cast doubt on reliability of verdict.