People of Michigan v. Ronald Duane Roseburgh
332041
| Mich. Ct. App. | May 16, 2017Background
- Defendant Ronald Roseburgh was arrested and processed at Berrien County Jail; six $50 bills were found in his pocket and placed in his inmate account envelope.
- Jail staff noticed the bills lacked ordinary security features; a detective confirmed the bills were counterfeit.
- After Miranda warnings, defendant was recorded admitting he knew the bills were fake, that he bought them for $100, and that he intended to use them to pay his bond.
- Defendant also told his girlfriend (in person at arraignment and by phone) he had money from under his mattress to cover part of his bond.
- At trial the recorded interview and witness testimony were played to the jury; defendant argued his statements were contradictory and did not prove intent to pass the bills.
- The jury convicted defendant of possession of counterfeit currency (MCL 750.254); he was sentenced as a fourth-offense habitual offender to 12 months–10 years; defendant appealed claiming insufficient evidence of intent to utter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove defendant intended to utter/pass counterfeit bills | Prosecution: recorded admissions and conduct show intent to use bills to pay bond | Roseburgh: statements were contradictory and insufficient to prove intent to pass | Court: Evidence (admissions, acts, and circumstantial proof) was sufficient to prove intent |
Key Cases Cited
- People v Meissner, 294 Mich. App. 438 (2011) (standard of review for sufficiency — review de novo; view evidence in light most favorable to prosecution)
- People v Hawkins, 245 Mich. App. 439 (2001) (intent may be inferred from words, acts, and circumstantial evidence)
- People v Carines, 460 Mich. 750 (1999) (proof beyond a reasonable doubt standard and deference to jury on credibility)
- People v Eisen, 296 Mich. App. 326 (2012) (appellate court will not reassess witness credibility)
- People v Hardiman, 466 Mich. 417 (2002) (factfinder determines permissible inferences from evidence)
- People v Harrison, 283 Mich. App. 374 (2009) (elements of MCL 750.254: possession, intent to utter/render, and knowledge of counterfeit)
- People v Kanaan, 278 Mich. App. 594 (2008) (conflicts in evidence resolved in favor of the prosecution)
- Miranda v Arizona, 384 U.S. 436 (1966) (Miranda warnings required before custodial interrogation)