AWIGBH sufficiency; People v Brown; Intent to do great bodily harm; People v Stevens; Bench trial; Findings of fact & conclusions of law; MCR 2.517(A)(1); People v Parkinson

The court held that sufficient evidence supported defendant-Raymond’s AWIGBH conviction and that the trial court’s factual findings and legal conclusions were adequate to support defendant-Rashard’s AWIGBH conviction after the bench trial. Defendants were involved in a long-running neighborhood dispute with the victims, S and B, that culminated in a fight. After Raymond confronted S, Rashard crossed the street and punched him, and S testified that both defendants later kicked him in the head while he was on the ground, leaving him with a concussion, trauma, contusions, and a shoulder injury. On appeal, the court held that the evidence against Raymond was sufficient because a rational factfinder could infer an intent to do serious injury of an aggravated nature from his forcible kicks to S’s head, the resulting injuries, and the parties’ history of hostile encounters, including prior threats. The court noted that even a single forceful kick to the head could support the required intent, particularly given Raymond’s statement during the confrontation: “I told you what I would do to you if you called the police on me again.” The court next held that Rashard’s challenge to the trial court’s findings failed because the court specifically found that he kicked S in the head and explained that repeated kicks to the head causing injuries serious enough to require ambulance transport demonstrated the required intent. It also rejected the claim that the trial court improperly relied on an aiding-and-abetting theory, noting that the trial court expressly recognized defendants were “not charged that way.” Affirmed.