People of Michigan v. James Edward White, 329108

Shooting at a Detroit car wash on Aug. 9, 2014; eyewitness Terria Desfernandez testified she saw defendant James White pull a black handgun, point it at her car, and fire 4–5 wild shots; no one was injured.
Ronald Curry (friend of victim and defendant) testified contrary to Desfernandez: he said White did not possess a gun that night; defense also called the defendant’s girlfriend who denied gun possession.
Defendant was charged with AWIM, AWIGBH (lesser included), felonious assault, felon-in-possession (MCL 750.224f), and felony-firearm (MCL 750.227b); jury acquitted on assault counts but convicted on felon-in-possession and felony-firearm.
Parties stipulated defendant had a prior felony conviction making him ineligible to possess firearms; the jury’s verdict provided the factual predicate for both convictions.
At trial the judge extensively questioned Curry; defendant did not object at trial (issue raised on appeal as unpreserved).
Sentence: as a fourth habitual offender, defendant received 2–15 years for felon-in-possession (minimum 24 months within the 12–48 month guidelines range) plus 2 years for felony-firearm; defendant appealed arguing judicial bias, an unreasonable sentence under Lockridge/Milbourn, and insufficient evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial bias from judge’s extensive questioning of Curry	Court’s questioning was permissible to clarify testimony and elicit relevant facts	Judge acted as prosecutor, creating appearance of partiality and denying fair trial	No plain error; questions were aimed at clarification, not advocacy; totality of circumstances showed no bias; verdict stands
Reasonableness of sentence post-Lockridge	Sentence within guidelines is presumptively proportional; Lockridge review for reasonableness applies to departure sentences only	Lockridge requires reasonableness review even for within-guidelines sentences; sentence disproportionate under Milbourn	Affirmed: sentence fell within guidelines (12–48 mos); Lockridge reasonableness review applies to departures; MCL 769.34(10) mandates affirmance absent scoring errors or inaccurate information
Sufficiency of the evidence for gun possession (felon-in-possession and felony-firearm)	Jury could credit eyewitness Desfernandez who plainly testified she saw White with a handgun and saw him fire	Defense pointed to Curry and other testimony denying gun possession and suggested eyewitness uncertainty	Affirmed: viewing evidence in light most favorable to the prosecution, Desfernandez’s unambiguous testimony sufficed; credibility conflicts were for the jury

People v. Stevens, 498 Mich 162 (clarifies permissible scope of judicial questioning and when questioning may show partiality)
People v. Carines, 460 Mich 750 (plain-error standard for unpreserved constitutional claims)
People v. Lockridge, 498 Mich 358 (holding Michigan guidelines advisory post-Apprendi/Alleyne; reasonableness review for departures)
People v. Milbourn, 435 Mich 630 (proportionality principle guiding sentencing review)
People v. Armisted, 295 Mich App 32 (court must affirm within-guidelines sentences absent scoring errors or inaccurate information)
People v. Jackson, 292 Mich App 583 (standard for preserving judicial-bias claims)