Brady v Maryland; Impeachment evidence; MRE 608; MRE 609; MRE 613; Judicial impartiality; People v Stevens; Ineffective assistance of counsel; Failure to move to suppress; Fourth Amendment; Terry v Ohio; Reasonable suspicion; Concealed pistol license (CPL); MCL 28.425f; People v Williams; Second Amendment; New York State Rifle & Pistol Ass’n, Inc v Bruen; Probation term; MCL 771.2(1); Great weight of the evidence

The court held that defendant failed to establish a Brady violation, judicial partiality, ineffective assistance, or a great-weight basis for relief, but that his probation term had to be reduced to three years. He was convicted of felony-firearm, FIP, and CCW after officers testified that he possessed and discarded a firearm. The trial court denied his posttrial motions alleging undisclosed impeachment evidence about one officer (A), ineffective assistance for failing to seek suppression, and a verdict against the great weight of the evidence. On appeal, the court first rejected defendant’s Brady claim because the undisclosed evidence about A’s employment history and unrelated misconduct was not favorable. It reasoned he failed to show the evidence involved “lying or a character for untruthfulness,” and he did not show the officer “lied under oath” rather than made honest mistakes in an unrelated deposition. The court also concluded the evidence was not material because another officer’s testimony “corroborated that of” A in most relevant respects. The court next held that the judge did not pierce the veil of impartiality because the challenged comments reflected trial management, were directed at repetitive questioning, and did not show “deep-seated favoritism or antagonism.” The court rejected defendant’s ineffective-assistance claim because a suppression motion would have failed. Under Williams, officers had reasonable suspicion after seeing an extended magazine and a black object at defendant’s waistband, and counsel was not deficient for failing to advance a “novel legal argument” under Bruen. But the court held that the four-year probationary term exceeded the statutory three-year maximum, requiring an amended probation order. It finally rejected the great-weight challenge because the prosecution’s case did not depend solely on one officer, and the other officer corroborated the key testimony. Affirmed in part and remanded for entry of an amended probation order.