Right to present a defense; People v. King; Limitations on cross-examination; Right of confrontation; People v. Taylor; Evidence about criminal activity in the area; Pre-trial letter that defendant’s girlfriend wrote to defense counsel; Joinder; Claim that the charges were not related under MCR 6.120; People v. Williams; Effect of the fact the underlying acts were committed on different days; Claim that prosecutor engaged in misconduct during the direct examination of the detective; People v. Waclawski; Ineffective assistance of counsel; Failure to file a notice of alibi; People v. Dixon; Sentencing; Scoring of OV 14; People v. Rhodes (On Remand); Costs; People v. Carines; People v. Cunningham; People v. Konopka; State Police Strike Team Investigative Narcotics Group (STING); Confidential informant (CI)

[Unpublished opinion.] The court held that the defendant failed to show that the trial court erred as to its evidentiary rulings during defense counsel’s cross-examination of the witnesses. Thus, he was not denied his right of confrontation or his right to present a defense. Also, the trial court did not err in excluding evidence about criminal activity in the area or a pre-trial letter that defendant’s girlfriend (W) wrote to defense counsel. Further, the court did not abuse its discretion by joining the cases. The prosecutor did not engage in misconduct, and defendant was not denied the effective assistance of counsel. The court also upheld the scoring of 10 points for OV 14 in sentencing defendant. Thus, it affirmed his convictions of delivery of less than 50 grams of a controlled substance and his sentences. However, it remanded for the trial court to articulate a factual basis to support the amount of costs imposed. He was convicted for delivering heroin to a CI who was working with officers from the STING. Defendant argued, among other things, that the trial court improperly limited his cross-examination of Detective L, the CI, W, and Officer K. He asserted that by limiting his ability to cross-examine the witnesses, the trial court denied him his constitutional rights of confrontation and to present a defense. The court held that defense counsel’s cross-examination about the CI’s “ability to respond to questions and to drive while under the influence of heroin was irrelevant under MRE 401 and properly excluded.” L’s testimony as to “whether heroin generally impairs a person’s ability to drive was not relevant in determining whether defendant delivered heroin” to the CI. The trial court’s decision “did not limit defendant’s ability to attack” the CI’s credibility. Evidence was admitted that the CI “was a heroin addict who had heroin in his vehicle during the traffic stop, and defense counsel highlighted testimony from” L and K that the CI stated he “would do whatever he had to do to stay out of trouble.” Thus, counsel was able to argue that the CI was not credible and was biased against defendant. Any evidence as to the CI’s “driving ability was not relevant to the outcome of the case or in determining whether he was a credible witness. Thus, defendant’s right to confrontation and to present a defense were not denied by” the trial court’s exclusion of the evidence.