People of Michigan v. Carl Marshall Price, 344931

On August 18, 2016, Robert Wray was fatally shot in front of defendant Carl Price’s home; Price admitted firing a .45 but claimed he acted in self‑defense and to protect others.
Prior to the shooting Wray returned home intoxicated, changed into dark clothing, and retrieved a 9 mm gun and mask; he confronted men playing basketball outside Price’s house.
A struggle occurred over Wray’s 9 mm, multiple shots were fired from at least three weapons (.45, 9 mm, and .40), and Wray suffered six gunshot wounds including a fatal head wound; ballistics tied eight .45 casings to Price’s gun and five 9 mm casings to a 9 mm found under Wray.
Price initially gave inconsistent statements to police about his role and knowledge of other shooters, later admitting he joined the group, felt a bullet graze his leg, saw Wray start to stand, and shot repeatedly.
Price was charged with second‑degree murder and felony‑firearm; a jury convicted him of voluntary manslaughter and felony‑firearm. He was sentenced to 86–180 months plus a consecutive two‑year term and appealed.
On appeal Price argued (1) the evidence was insufficient because the prosecution failed to disprove his claim of self‑defense, and (2) the prosecutor committed misconduct in closing argument by vouching for witnesses and denigrating him.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence re: self‑defense	Prosecution: ballistics and inconsistent statements disprove Price’s self‑defense claim; other shooters and .40 caliber evidence undercut necessity/credibility	Price: produced prima facie self‑defense evidence (intoxicated, armed victim, struggle, grazed leg), shifting burden to prosecution to disprove self‑defense beyond a reasonable doubt	Affirmed: viewed in prosecution’s favor, jury could reject Price’s account; evidence sufficed to disprove self‑defense beyond a reasonable doubt
Prosecutorial misconduct in closing (vouching/denigration)	Prosecution: rebuttal comments were proper arguments on credibility and evidence, not improper vouching or character attacks	Price: prosecutor vouched for witness credibility and improperly denigrated him, warranting reversal	Affirmed: no plain error; statements were proper comment on evidence and reasonable rebuttal, not impermissible vouching or prejudicial denigration

People v Hampton, 407 Mich. 354 (recognizing due‑process requirement that every element be proved beyond a reasonable doubt)
People v Dupree, 486 Mich. 693 (describing defendant’s initial burden to produce prima facie self‑defense and prosecution’s burden to disprove it beyond a reasonable doubt)
People v Reese, 491 Mich. 127 (defining voluntary manslaughter and how provocation negates malice)
People v Oros, 502 Mich. 229 (standard of review for sufficiency of the evidence — view evidence in light most favorable to the prosecutor)
People v Bahoda, 448 Mich. 261 (prohibiting prosecutor vouching for witness credibility)
People v Unger, 278 Mich. App. 210 (standard for reversal for prosecutorial misconduct — plain error affecting substantial rights)
People v Stevens, 306 Mich. App. 620 (defendant’s obligation to produce prima facie self‑defense evidence)