People of Michigan v. John Eric Parsons, 333021

Late-night encounter: Deputy Hilliker spotted Parsons’ vehicle parked with headlights off on an unlit dirt access road outside a closed store in an area known for drug activity and prior break-ins.
Upon Hilliker’s approach Parsons turned headlights on, drove past, accelerated loudly, and made evasive turns; Hilliker activated lights and siren and Parsons turned his headlights off and fled.
Parsons led police on a 30+ minute high-speed chase, committing traffic violations and throwing items (later admitted to be marijuana and a pipe) from the vehicle.
Officer rammed Parsons’ truck to stop it; Parsons’ truck rolled onto its side; officers observed open beer containers, smelled alcohol, found marijuana on Parsons, and Parsons admitted drinking and earlier marijuana use.
Parsons failed one HGN-type tracking test, was handcuffed after the collision, and consented to blood testing: BAC 0.058 g/100 mL and 7 ng/mL THC (consistent with use 8–12 hours earlier).
Procedural posture: Motion to suppress denied; bench trial convictions for third-degree fleeing and eluding, possession of a controlled substance, operating with a suspended license, and operating while intoxicated; sentence as fourth habitual offender affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable, articulable suspicion to initiate a stop (Terry stop)	Hilliker had reasonable suspicion based on parked car in dark area known for drug activity, defendant’s abrupt driving away and loud acceleration, and apparent attempt to avoid contact	Parsons argued the officer lacked reasonable suspicion; his actions did not amount to unprovoked flight or other specific facts supporting a stop	Court held totality of circumstances supported reasonable suspicion; suppression denied
Whether evidence was sufficient to convict for operating while intoxicated	Prosecution relied on open containers, odor of alcohol, admissions of drinking and marijuana use, failed sobriety test, reckless driving during chase, and blood test showing alcohol + THC	Parsons argued BAC below .08 and THC presence alone did not prove impairment	Court held circumstantial evidence and reasonable inferences sufficed to prove impairment beyond a reasonable doubt
Whether verdict was against the great weight of the evidence	Prosecution: evidence overwhelmingly supported convictions	Parsons: verdict contrary to weight of evidence given low BAC and THC timing	Court rejected claim; evidence did not weigh so heavily against verdict to amount to miscarriage of justice

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory stop standard requiring reasonable, articulable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (2000) (unprovoked flight in high-crime area can support reasonable suspicion)
People v. Oliver, 464 Mich. 184 (2001) (totality of circumstances; flight supports investigatory stop)
People v. LoCicero, 453 Mich. 496 (1996) (fewer facts required to stop a moving vehicle than for a residence; officer must draw specific inferences)
People v. Borchard-Ruhland, 460 Mich. 278 (1999) (warrantless searches/seizures presumptively unreasonable)
People v. Barbarich, 291 Mich. App. 468 (2011) (Terry stop principles applied under Michigan law)
People v. Roberts, 292 Mich. App. 492 (2011) (standard of review for suppression rulings)
People v. Ericksen, 288 Mich. App. 192 (2010) (standard for sufficiency of the evidence review)
People v. Solmonson, 261 Mich. App. 657 (2004) (circumstantial evidence and reasonable inferences can support conviction)
People v. Lambert, 395 Mich. 296 (1975) (defines “under the influence” as substantially and materially affecting driving)
People v. Calvin, 216 Mich. App. 403 (1996) (BAC is not an element; observer testimony can establish intoxication)
People v. Musser, 259 Mich. App. 215 (2003) (standard for a verdict being against the great weight of the evidence)