Search-warrant probable cause & nexus; MCL 780.651; People v Franklin; Staleness of firearm information in warrant; MCL 780.653; People v Brown; No-knock warrant & knock-and-announce exception; MCL 780.656; People v Vasquez; Expert meth-distribution opinion & drug-profile evidence; MCL 333.7401; People v Murray; Sufficiency of evidence & great-weight challenge; MCL 333.7214; People v Harris; Speedy-trial; Barker factors; MCL 768.1; People v Williams; Plea/sentence agreement violation & remedy; MCL 769.12; Santobello v New York; Within-guidelines sentence proportionality; MCL 769.34; People v Steanhouse

The court held that defendant’s convictions and within-guidelines sentences for meth and firearm offenses were properly affirmed because the search warrant, trial rulings, and sentencing decisions complied with constitutional and statutory requirements. Officers executed a no-knock warrant at defendant’s residence and associated vehicles, finding more than 10 grams of meth, a scale with residue, small baggies, and multiple loaded firearms and ammunition in a backpack containing defendant’s identification. A jury convicted him of possession of meth with intent to deliver, multiple FIP counts, FIP of ammunition, and felony-firearm, and the trial court sentenced him as a fourth-offense habitual offender to concurrent prison terms with additional consecutive felony-firearm terms. On appeal, the court held that the affidavit provided a “substantial basis” for probable cause, tying drug trafficking and firearm use to defendant, his SUV, and the address at issue, and that the nine-day-old firearm information was “not stale” given the nature of guns. It rejected challenges to the search of another vehicle on the property for lack of standing and because it was a vehicle “associated to or on the property.” The court also upheld limits on cross-examination, admitted the narcotics expert’s opinion that the meth was “for sales and distribution,” found the evidence sufficient and not against the great weight, found no speedy-trial violation or additional remedy beyond plea withdrawal for a breached sentence agreement, and concluded the within-guidelines sentence was proportionate in light of defendant’s record and risk to the community. Affirmed.