Sufficiency of the evidence; Criminal contempt for violating a PPO; MCL 600.2950a(23); In re JCB

The court held that the evidence was sufficient to find respondent guilty of criminal contempt for violating a PPO. The trial court found he violated the PPO by making a threatening telephone call to petitioner, his sister. It sentenced him to one day in jail, but “suspended the jail term with a stern warning” about the penalties for committing any further violations of the PPO. On appeal, the court rejected his argument that the evidence was insufficient to support a finding of criminal contempt. First, “petitioner’s testimony constituted competent evidence to support the trial court’s finding that” respondent made the threatening call. Second, “[t]he prosecution had no legal obligation to provide testimony from anyone other than petitioner to establish that the call occurred and that” respondent made it. Third, “the prosecution elected to proceed to trial without any forensic analysis of [respondent’s] phone but nonetheless convinced the trial court beyond a reasonable doubt that” he made the call. The court found “no basis to conclude that the trial court” erred in this regard. Affirmed.