People of Michigan v. James Andrew Stevens Jr, 331960

On Sept. 2, 2015, James Stevens (20) returned home intoxicated, argued with his mother, broke a glass bowl, and head-butted her during an escalating confrontation.
After being slapped, kicked, and struck with a broom by his mother during the altercation, Stevens left briefly and then returned, forcefully opening the door and damaging drywall.
Deputies arrived, spoke with the mother and sister, determined to detain Stevens for domestic violence, and attempted to place him in a patrol car.
Stevens resisted, cursed, and physically fought the deputies; a deputy deployed a Taser twice and later discovered a chipped tooth requiring dental repair.
A jury convicted Stevens of MCL 750.81d(2) (resisting/obstructing an officer causing injury) and MCL 750.81d(1) (resisting/obstructing an officer).
On appeal Stevens argued (1) the trial court omitted an essential jury instruction that the arrest must be lawful and (2) the evidence was insufficient to support the felony conviction for causing injury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to instruct the jury that an arrest must be lawful as an element of resisting/obstructing an officer	The People argued the omission was harmless because the arrest was lawful based on the information available to deputies	Stevens argued the court should have instructed that the officers’ actions (arrest) had to be lawful; omission required a new trial	Court: Instruction omission was error but harmless; probable cause existed so the omitted instruction would not have changed the verdict
Whether evidence was sufficient to sustain the felony conviction under MCL 750.81d(2) (injury requiring medical attention)	The People contended the deputy’s chipped tooth that required dental treatment satisfied the statute’s medical-attention requirement	Stevens contested sufficiency of evidence for injury element and/or other elements	Court: Evidence sufficient; deputy sought and received dental care, meeting the statutory requirement for bodily injury requiring medical attention

People v Gillis, 474 Mich. 105 (discussing review of jury instruction challenges)
People v Quinn, 305 Mich. App. 484 (resisting/obstructing officer elements include lawfulness of officer’s actions)
People v Riddle, 467 Mich. 116 (defendant bears burden to show omitted instruction caused miscarriage of justice)
People v Cohen, 294 Mich. App. 70 (probable cause judged from totality of circumstances)
People v Solloway, 316 Mich. App. 174 (standard for sufficiency review)