Sufficiency of the evidence for meth possession conviction; MCL 333.7403(2)(b)(i); People v Oros; Knowledge element; People v McFarlane; Ineffective assistance of counsel; Conflict of interest; MRPC 1.9(a); Mickens v Taylor; Juror bias; People v Unger; Preparation & trial strategy; People v Payne

The court held that the evidence was sufficient to prove defendant knowingly possessed meth and he failed to establish ineffective assistance of counsel. Meth was discovered in his overalls during a search incident to arrest on an outstanding warrant after officers responded to a complaint at his property. He testified he found the overalls in an abandoned vehicle and had worn them only twice, claiming he did not know meth was in the pockets. The trial record showed he kept personal items in the same overalls, including paperwork, cash, pills, and a pill bottle found in the pocket with the meth. On appeal, the court held that the knowledge element could be proven with “minimal circumstantial evidence,” and the jury could reasonably infer that after two days of wearing the overalls and using the pockets, he either placed the meth there or “knew of the meth[] and decided to continue carrying it.” He also claimed counsel was ineffective due to a prior divorce representation, a juror he said was a former financial planner, and inadequate preparation. The court found no actual conflict because counsel did not “actively represent[] conflicting interests,” and he did not show prejudice. It credited the trial court’s finding that counsel was credible, including testimony that he never disclosed any relationship with the juror. The court also found counsel’s choices were “sound trial strategy,” including how counsel handled the TruNarc (a narcotics analyzer) timing issue and fingerprint requests. Affirmed.