Sufficiency of the evidence for a resisting or obstructing a police officer (R&O) conviction; MCL 750.81d(1); People v Corr; “Obstruct” (MCL 750.81d(7)(a))

Holding that the evidence was sufficient to allow “a reasonable juror to conclude, beyond a reasonable doubt, that defendant committed the offense of R&O because, at minimum, he failed to follow a lawful command[,]” the court affirmed. He was also convicted of third-degree fleeing and eluding and misdemeanor domestic violence. The case arose from an incident in which a county park ranger (D) attempted to stop defendant’s vehicle after being asked for help by a woman who had exited that vehicle. She told D that defendant had a gun. On appeal, defendant only challenged the sufficiency of the evidence for his R&O conviction, asserting the prosecution did not show that he heard D’s verbal command to stop. D “testified that the window on his patrol vehicle was lowered, and so was the window on defendant’s vehicle. He further testified that defendant drove his vehicle very slowly past the patrol vehicle, coming within six or seven feet. While defendant was passing the patrol vehicle,” he was looking right at D, who instructed him “to stop. But defendant did not stop his vehicle.” He instead drove it into a liquor store parking lot. D made “a U-turn, maneuvered behind defendant’s vehicle, and activated his overhead lights. Defendant fled in his vehicle, so [D] activated his siren and engaged in a pursuit. Defendant eventually stopped” and was arrested. Given D’s testimony, the court rejected defendant’s claim that the record did not contain sufficient evidence to support his R&O conviction.