Sufficiency of evidence; Disturbing the peace; MCL 750.170; “Disturbance”; People v Mash; Resisting or obstructing a police officer; MCL 750.81d(1); Lawful command; MCL 750.81d(7)(a); People v Vandenburg; Indigency screening; MCR 6.005(B)

The court held that sufficient evidence supported defendant’s convictions of disturbing the peace and resisting or obstructing a police officer, and that the trial court complied with MCR 6.005(B). Defendant entered a township hall, yelled at and insulted employees, refused to leave after being asked, and later refused an officer’s command to go. The jury convicted him of disturbing the peace and resisting or obstructing Officer S, and the trial court denied his posttrial motion for a directed verdict or new trial. On appeal, the court first held that sufficient evidence supported the disturbing-the-peace conviction because witnesses testified defendant aggressively yelled, used vulgar terms, threatened employees by saying he knew where they lived, poked an employee with a pen, and made multiple employees uncomfortable enough to call police or seek help. This evidence supported a finding he disrupted an otherwise quiet township hall and was not “merely stating his position or opinion.” The court also held that sufficient evidence supported resisting or obstructing because Officer S told defendant “you gotta go,” which “cannot be characterized as anything but a command,” and defendant knowingly failed to comply for more than 30 seconds before the officer touched him. The officer’s lawful command, defendant’s refusal, and his undisputed knowledge that Officer S was a police officer performing his duties allowed a rational jury to find the elements proved. Finally, the court held that the trial court referred defendant for indigency screening by identifying the public defender, explaining the screening process, and telling him he needed to contact that office if he wanted help obtaining an expert. Affirmed.