e-Journal Summary

e-Journal Number : 83833
Opinion Date : 06/11/2025
e-Journal Date : 06/25/2025
Court : Michigan Court of Appeals
Case Name : People v. White
Practice Area(s) : Criminal Law
Judge(s) : Per Curiam – Mariani, Maldonado, and Young
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Issues:

Sufficiency of the evidence; First-degree murder; Premeditation; Self-defense; Rule of completeness; MRE 106

Summary

Holding that: 1) there was sufficient evidence “to support a conviction of first-degree murder under a theory of premeditation[,]” 2) there was sufficient evidence to disprove his theory of self-defense, and 3) the “rule of completeness [was] not implicated, and defendant has failed to show error on its basis[,]” the court affirmed. He was convicted by a jury of first-degree premeditated murder, FIP, and felony-firearm. The record demonstrated “that there was sufficient evidence presented at trial from which a reasonable jury could determine that defendant ‘had an opportunity to think about, evaluate, or take a second look at [his] actions.’” The court noted that “the parties had a preexisting relationship; defendant and the victim were friends before the killing, and the victim regularly sold defendant marijuana. At the time of the victim’s death, defendant owed the victim $625 for unpaid marijuana sales.” Moreover, they “exchanged text messages in the week leading up to the victim’s death, which indicated that the victim was seeking out the unpaid debt and that defendant had attempted to visit the victim on the day before the killing. Defendant also admitted that he deliberately brought a gun to the victim’s home on the night he shot the victim. And, the evidence presented at trial would allow a reasonable jury to infer that, contrary to defendant’s version of events, the victim was unarmed at the time of his death—the only weapons found in the victim’s home were two handguns stored in lockboxes inside a closet, and police found only a vape pen in the hand of the victim.” Finally, the court noted that “the evidence established that defendant fired his gun several times (the victim’s autopsy report revealed seven gunshot wounds) and from as close as 2½ to 3 feet away from the victim.” It concluded that the “evidence, when viewed (as it must be) in the light most favorable to the prosecution, was sufficient to permit a jury to conclude beyond a reasonable doubt that defendant acted with premeditation in shooting the victim.” Next, the court found that from the “evidence, a reasonable jury could conclude that defendant’s self-defense theory was not credible.” The court noted that it “will not interfere with such a credibility determination.” It concluded that the “record, when viewed in the light most favorable to the prosecution, shows that the prosecution satisfied its burden of disproving defendant’s self-defense claim beyond a reasonable doubt.”

Full PDF Opinion