People of Michigan v. Lameke Latrice Bailey, 330748

Police were dispatched to a reported domestic disturbance and assault; officers arrived at 2920 Reynolds late at night and heard loud banging and sounds of a fight inside.
Officers knocked, announced themselves, received no response, and entered the open-front-door residence without a warrant, invoking the emergency-aid justification.
Inside, two women (defendant’s mother Jolene and sister Turquoise) were on top of Bailey; officers told them to release Bailey, who then stood, threatened to fight, picked up a heavy glass/ceramic lamp, and swung it at officers.
Officers ordered Bailey to drop the lamp multiple times; she barricaded in a bedroom, swung the lamp striking Officer Anderson’s arm, and resisted being handcuffed before officers subdued and arrested her.
A jury convicted Bailey of assaulting/resisting/obstructing a police officer (MCL 750.81d(1)) and felonious assault (MCL 750.82); she was sentenced to concurrent jail terms and probation. She appealed raising Fourth Amendment (entry/standing), evidentiary, testimonial, and ineffective-assistance claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry / standing	Entry was lawful under the emergency-aid exception; officers reasonably believed someone needed immediate aid.	Entry was unlawful; Bailey could resist an unlawful entry and arrest.	Court: Bailey lacked standing to challenge entry; even if she had standing, entry was lawful under emergency-aid exception. Affirmed.
Sufficiency of felonious-assault evidence	Lamp was used as a dangerous weapon; swinging it constituted an attempt and battery with intent or to create apprehension.	Evidence insufficient (implicit).	Court: Evidence sufficient for felonious assault—lamp was a dangerous weapon and intent can be inferred.
Exclusion / nonproduction of res gestae witness (Jolene)	Prosecution complied with res gestae notice; defense declined to call Jolene.	Trial court denied Bailey’s right to present defense by excluding Jolene.	Court: Defense counsel waived Jolene’s testimony as tactical decision; no error preserved.
Right to testify / ineffective assistance of counsel	Bailey was prevented from testifying and counsel was ineffective for not calling Jolene or allowing her to testify.	Counsel advised Bailey; Bailey knowingly waived right to testify; counsel reasonably tried to contact Jolene and declined to call unvetted witness as strategy.	Court: No deprivation of right to testify (Bailey affirmed decision on record). Counsel’s strategic choices were reasonable; ineffective-assistance claims fail.

Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency-aid exception permits warrantless entry when officers reasonably believe persons inside need immediate aid)
Kyllo v. United States, 533 U.S. 27 (2001) (Fourth Amendment protects reasonable expectations of privacy; home is afforded special protection)
Payton v. New York, 445 U.S. 573 (1980) (Fourth Amendment draws a firm line at the entrance to the home)
Minnesota v. Olson, 495 U.S. 91 (1990) (overnight guest has expectation of privacy sufficient to challenge warrantless entry)
People v. Moreno, 491 Mich. 38 (2012) (right to resist unlawful entry/arrest remains recognized; conviction reversed where entry was unconstitutional and no exigency existed)
People v. Davis, 442 Mich. 1 (1993) (discusses emergency-aid and community-caretaking doctrines in Michigan)
People v. Quinn, 305 Mich. App. 484 (2014) (elements of assaulting/resisting/obstructing police include that officers acted lawfully)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel: deficient performance and prejudice)