Joinder; MCR 6.120(B) & (C); People v Williams; Harmless error; Sixth Amendment right to an impartial jury drawn from a fair cross-section of the community; People v Bryant; Duren v Missouri; Sufficiency of the evidence; Self-defense; MCL 780.972(1)(a)

The court held that (1) the trial court did not abuse its discretion in joining defendant’s two cases for one trial, (2) he was not entitled to relief based on the racial composition of the jury venire, and (3) a rational fact-finder could conclude that the prosecution disproved his self-defense claim beyond a reasonable doubt. In one of the cases, he was convicted of discharging a firearm from a motor vehicle causing serious bodily impairment, CCW, AWIGBH, and felony-firearm. In the other case he was convicted of assaulting, resisting, or obstructing a police officer and CCW. As to his joinder argument, the “July 11 charges arose directly from law enforcement’s attempt to arrest defendant on a warrant issued for the July 5 offenses. And while temporal proximity is not required to establish that offenses are related, . . . it is a relevant consideration under MCR 6.120(B)(1).” Further, the record supported “a reasonable inference that the semiautomatic handgun and extended magazine recovered during the arrest linked the offenses.” In addition, there was “significant overlapping proof. Defendant’s attempt to flee arrest on July 11 was admissible in connection with the July 5 offenses as ‘[e]vidence of flight[.]’” And because a showing that the officers acted lawfully when trying to arrest him was required for the resisting or obstructing charge, evidence explaining that they “were executing an arrest warrant based on the July 5 shooting was directly relevant to the July 11 charges.” As to his jury venire argument, he failed to satisfy “the second and third prongs of the Duren test.” Finally, the evidence he presented in support of his self-defense claim did not “create a reasonable belief that deadly force was necessary to prevent imminent death or great bodily harm to defendant or another person.” Further, even assuming that a witness’s “testimony and defendant’s statement to police were sufficient to establish a prima facie claim of self-defense, the prosecution presented ample evidence to disprove that defense beyond a reasonable doubt.” Affirmed.