Voir dire; Waiver; Cross-examination; MRE 611(c); Relevance; MRE 401 & 402; The harmless-error rule; MCL 769.26; People v Lukity; Sentencing; Scoring of OVs 4 & 10; Reasonableness & proportionality; People v Milbourn; Principle that the court must affirm a within-guidelines minimum sentence; MCL 769.34(10); Distinguishing People v Armisted; Substitute counsel; People v McFall

The court held that the trial court did not abuse its discretion by limiting voir dire, by precluding cross-examinations as to witness bias, or by denying defendant's request for substitute counsel. It also held that there were no errors in sentencing. He was convicted of AWIM for stabbing the victim. The trial court sentenced him, as a fourth-offense habitual offender, to 40 to 80 years. On appeal, the court rejected his argument that the trial court abused its discretion by “limiting the entirety of attorney voir dire to 15 minutes per side,” which “prevented defense counsel from adequately questioning prospective jurors to discover any biases or prejudices that might have warranted a challenge for cause or a peremptory challenge.” It noted that defendant misstated the record in this regard, and waived any error by failing to exhaust peremptory challenges and expressing satisfaction with the empaneled jury. The court also rejected his claim that the trial court abused its discretion by precluding cross-examinations regarding witness bias. “Given the overwhelming evidence of defendant’s guilt, and the minimal importance of witness credibility in resolving the principal issue of defendant’s intent, defendant has failed to demonstrate that the trial court’s exclusion of the disputed evidence was outcome-determinative.” It next rejected his contention that the trial court erred in scoring OVs 4 and 10, noting any alleged error did “not affect the applicable sentencing guidelines range.” The court further rejected his argument that his 40-year minimum sentence was disproportionate, noting that it was “within the appropriate guideline ranges,” and that under existing precedent, the court must affirm such a sentence. Finally, the court rejected his claim that the trial court abused its discretion by denying his pretrial request for new counsel. “Given that defendant was charged with a serious felony, the strength of the evidence against him, and that [his] request for the appointment of substitute counsel occurred just 14 days before trial began,” there was no error with the trial court’s conclusion that “the appointment of substitute counsel would have unduly delayed these proceedings.” Affirmed.