Jury trial; Voir dire time limit; MCR 6.412(C)(1); People v Washington; Assault; AWIGBH sufficiency; MCL 750.84; People v Brown; Intent element; Self-defense; MCL 780.972(2); People v Dupree; New trial; Great weight of the evidence; People v Lacalamita

The court held that the trial court did not err by limiting voir dire to 15 minutes per side, that sufficient evidence supported defendant’s AWIGBH conviction, and that the verdict was not against the great weight of the evidence. Defendant was convicted after a fight at his aunt’s house. His cousin M testified that defendant punched and kicked him, smashed his head against a table, and struck him with household objects, while defendant claimed that M hit him first and that he only punched him twice in response. M was taken to the hospital, received stitches for facial cuts, and testified that he continued to suffer psychological effects two years later. On appeal, the court held that the voir dire claim was unpreserved because defendant did not exhaust his peremptory challenges. Further, he failed to show error because the trial court’s 15-minute limit imposed no subject-matter restriction and still allowed counsel to question jurors about violence, credibility, self-defense, family disputes, and whether defendant had to testify. The court next held that sufficient evidence supported the intent element of AWIGBH because the jury could infer from the severity of M’s injuries, the blood at the scene, defendant’s statement that he had “knocked out” M and hit him “a couple times,” and the family feud that he intended to inflict serious injury of an aggravated nature. The court also held that the prosecution disproved self-defense because the jury was entitled to credit M and his family members, who testified that defendant was the aggressor. Affirmed.