People of Michigan v. Antjuan Edward Crump
335332
| Mich. Ct. App. | Dec 14, 2017Background
- On October 7, 2012, Stacey Paul Smith was shot and killed in Inkster, Michigan; Antjuan Edward Crump (defendant) and two co-defendants were present that evening.
- Defendant was tried and convicted of felon-in-possession (MCL 750.224f) and felony-firearm (MCL 750.227b); sentenced as a second-offense habitual offender to concurrent prison terms (30–90 months for felon-in-possession and 2 years for felony-firearm).
- Witnesses (Vyonna Smith, Darnell Smith, and Rodney Miller) testified defendant had firearms that night—testimony identified a handgun and an AK-47, though witness descriptions varied.
- Police recovered defendant’s coat near his wallet and a handgun magazine at the scene, which the jury could infer related to defendant.
- Defendant appealed, arguing (1) insufficient evidence that he possessed a firearm due to inconsistent witness testimony, and (2) the trial court gave an inconsistent jury instruction during deliberations.
- The Court of Appeals affirmed, holding the evidence sufficed to support possession and that any instructional error was waived by defense counsel’s agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that defendant possessed a firearm | Multiple eyewitnesses and physical evidence supported possession | Witness testimony was inconsistent about weapon type, so proof was insufficient | Affirmed: viewing evidence in prosecution’s favor, testimony and magazine/coat supported constructive/actual possession |
| Whether inconsistencies in witness testimony undermine jury verdict | Credibility/resolution of inconsistencies are for the jury; circumstantial evidence suffices | Inconsistencies create reasonable doubt about possession | Affirmed: inconsistencies did not require reversal; credibility determinations are for the jury |
| Jury instruction during deliberations inconsistent with prior instructions | Response correctly explained that felony-firearm may be predicated on murder or felon-in-possession | Instruction arguably suggested counts were linked improperly | Affirmed: defendant waived any instructional error by counsel’s express agreement; court’s answer accurately stated law |
Key Cases Cited
- People v Solloway, 316 Mich. App. 174 (discusses standard for sufficiency review)
- People v Reese, 491 Mich. 127 (sufficiency review—view evidence in prosecution’s favor)
- People v Hardiman, 466 Mich. 417 (factfinder determines inferences and witness credibility)
- People v Perkins, 262 Mich. App. 267 (elements of felon-in-possession)
- People v Bosca, 310 Mich. App. 1 (elements of felony-firearm possession)
- People v Johnson, 293 Mich. App. 79 (constructive possession principles)
- People v Passage, 277 Mich. App. 175 (appellate courts defer to factfinder on credibility/weight)
- People v Carter, 462 Mich. 206 (waiver by counsel’s satisfaction with instruction)
- People v Adams, 245 Mich. App. 226 (waiver extinguishes appellate review)
- People v Calloway, 469 Mich. 448 (felon-in-possession can serve as predicate for felony-firearm)