People of Michigan v. Darryl Elawrence Brown, 328299

On Sept. 17, 2014, Detroit undercover officers observed a known drug dealer enter a residence; officers followed and found defendant sitting in the dining room.
Officers testified defendant flung a pill bottle after being ordered to freeze; the bottle contained 37 separate zip‑locked packages of cocaine.
Defendant testified he was at the house to investigate electrical work and carried a pellet gun in a shoulder holster for self‑protection after a prior beating.
Defense sought to introduce a photograph of defendant’s post‑assault injuries to explain the pellet gun; the trial court excluded the photo.
A jury convicted defendant of possession with intent to deliver <50 grams of cocaine; he was sentenced to five years’ probation (first six months in jail).
Defendant appealed, arguing (1) improper exclusion of the injury photograph and (2) insufficient evidence of possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of photograph showing prior injuries	Photo was irrelevant; prosecution maintained it did not relate to elements of charged offense	Photo was relevant to show reason for carrying pellet gun (self‑defense) and rebut implication he was a dealer; admissible to explain conduct	Court: Photo not relevant to material fact (possession); trial court did not abuse discretion in excluding it
Sufficiency of evidence of possession	Officers’ testimony and physical evidence (pill bottle with 37 baggies) plus location in known drug house sufficed to prove knowing possession with intent to deliver	Defendant’s testimony denied possession and claimed lawful purpose for presence; appellee urged conviction supported by circumstantial evidence	Court: Viewing record in prosecution’s favor, evidence was sufficient to sustain conviction beyond a reasonable doubt

Starr v. People, 457 Mich. 490 (discussing appellate review for abuse of discretion) (Mich. 1998)
Bahoda v. People, 448 Mich. 261 (establishing standards for admission/rejection of evidence) (Mich. 1995)
Coddington v. People, 188 Mich. App. 584 (photographic evidence reviewed for abuse of discretion) (Mich. Ct. App. 1991)
Mills v. People, 450 Mich. 61 (two‑step test for admissibility: relevance then Rule 403 analysis) (Mich. 1995)
McKinney v. People, 410 Mich. 413 (materiality defined for relevance) (Mich. 1981)
Wolfe v. People, 440 Mich. 508 (elements of possession with intent to deliver) (Mich. 1992)
Meissner v. People, 294 Mich. App. 438 (standard of review for sufficiency of evidence) (Mich. Ct. App. 2011)
Reese v. People, 491 Mich. 127 (viewing evidence in light most favorable to prosecution) (Mich. 2012)
Johnson v. People, 460 Mich. 720 (due process requires sufficient evidence for conviction) (Mich. 1999)
Avant v. People, 235 Mich. App. 499 (credibility and intent for jury determination) (Mich. Ct. App. 1999)
Carines v. People, 460 Mich. 750 (circumstantial evidence and inferences can support conviction) (Mich. 1999)
Terry v. People, 224 Mich. App. 447 (conflicts in evidence resolved for prosecution on appeal) (Mich. Ct. App. 1997)
Milstead v. People, 250 Mich. App. 391 (appellate court will not reweigh witness credibility) (Mich. Ct. App. 2002)