People of Michigan v. Edward Minaskar Beamon, 332509

Defendant Beam on and cousin Demont Barnes were driving when they spotted McKinney and Clark; Barnes testified defendant chased them on foot and fired, killing McKinney.
Clark survived; Barnes claimed the nightclub dispute motivated retaliation, possibly by mistaken identity.
Barnes pled guilty to second-degree murder and testified against Beam on.
Defendant was charged with conspiracy to commit first-degree murder, first-degree murder, assault with intent to murder, and three felony-firearm counts; sentenced as fourth habitual offender to concurrent life terms and up to 15 years for the assault count, with five-year terms on the firearms counts.
On appeal, Beam on challenges sufficiency of evidence, admissibility of jail kites, prosecutorial error, transcript issues, and ineffective assistance claims; the appellate court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of assault with intent to murder	Beam on argues insufficient intent to kill Clark.	Beam on contends lack of proof of intent to kill Clark.	Sufficient evidence supports intent to kill Clark.
Sufficiency of conspiracy to commit first-degree murder	Evidence shows agreement to retaliate and further the unlawful objective.	No explicit or implicit agreement shown to commit murder.	Sufficient evidence of conspiracy found.
Admission of kites as authenticated evidence	Notes to Barnes corroborate defendant wrote them; authentication enough.	Kites were unauthenticated and unsigned.	Notes sufficiently authenticated; admission not error affecting outcome.
Prosecutorial error	Prosecutor improperly described evidence and appealed to sympathy.	Remarks were prejudicial and unsupported by evidence.	No reversible prosecutorial error; instructions mitigated prejudice.
Ineffective assistance / transcript issues	Counsel failed to move for mistrial based on a possible innocent statement by Barnes.	Counsel deficient for not seeking mistrial; transcript issues unresolved.	No reversible error; record insufficient to show ineffective assistance or harmful transcript inaccuracy.

People v Ericksen, 288 Mich App 192 (2010) (sufficiency review standard)
People v Hampton, 407 Mich 354 (1979) (due process requires proof beyond a reasonable doubt)
In re Winship, 397 U.S. 358 (1970) (beyond a reasonable doubt standard)
People v Carines, 460 Mich 750 (1999) (standard for reviewing evidentiary sufficiency and errors)
People v Henderson, 306 Mich App 1 (2014) (minimal circumstantial evidence may prove intent)
People v Unger, 278 Mich App 210 (2008) (consciousness of guilt inferences from flight, lying)
People v Lowery, 274 Mich App 684 (2007) (circumstantial evidence and conspiracy proof )
People v Izarraras-Placante, 246 Mich App 490 (2001) (necessary to show specific intent for conspiracy)
People v Blume, 443 Mich 476 (1993) (definition of conspiracy and party to the unlawful objective)
People v Lukity, 460 Mich 484 (1999) (harmless error standard)
People v Ginther, 390 Mich 436 (1973) (Ginther standard for postconviction evidentiary hearings)
People v Abdella, 200 Mich App 473 (1993) (Abdella requirements for transcript accuracy claims)
People v Budzyn, 456 Mich 77 (1997) (prosecutorial misconduct standards; extraneous statements)
People v Wise, 134 Mich App 82 (1984) (prosecutorial remarks and sympathy arguments)
People v Fisher, 193 Mich App 284 (1992) (limits on prosecutorial argument)