Sufficiency of the evidence; Self-defense; The Self-Defense Act; MCL 780.972(2); Effect of defendant’s contentious history with the victim; Distinguishing People v Cooper & People v Harris

Holding that the jury was presented with sufficient evidence to disprove defendant’s self-defense claim beyond a reasonable doubt, the court affirmed her convictions of felonious assault, using a self-defense spray device, and assault and battery. The victim (I) worked as the community/property manager for the mobile home park from which defendant was evicted in 2023. “Despite her eviction, defendant at times returned to” the park and interacted with I. They “had contentious interactions at times over the next year,” and the incident giving rise to the case occurred in 2024. The court noted that while “defendant claimed she honestly and reasonably believed [I] was holding mace and was about to spray her with it, the video of the incident clearly shows [I] holding her lanyard, with the teal object believed to contain mace dangling below it, alongside the rest of her keychain. Even if defendant thought [I] was carrying mace, the mere possession of a weapon by another does not mean there was insufficient evidence supporting the jury’s verdict.” In addition, evidence that “defendant asked or urged the victim to come closer weighs against a claim that the defendant honestly and reasonably believed that the use of force was necessary.” The cell phone video of the incident showed that defendant called I “over to her vehicle, [I] walked closer to defendant, and defendant sprayed her.” Instead of driving away, she suggested that I come closer. In asserting that her contentious history with I supported “that she had an honest and reasonable fear of” her, defendant cited Cooper and Harris. The court found those cases distinguishable. The trial court in this case admitted “some evidence of the parties’ prior interactions and [I’s] reputation as known to defendant. Moreover, in neither Harris nor Cooper did the court reverse a jury verdict based on insufficient evidence to disprove a claim of self-defense.”