People of Michigan v. Steven Allen Seay Jr, 332004

Steven Allen Seay, Jr. was convicted by a jury of felony-firearm (second offense), carrying a concealed weapon, felon in possession of a firearm, felon in possession of ammunition, and driving with a suspended license; sentenced as a fourth habitual offender.
At traffic stop/consent search officers found a firearm and a small bag of pills together beneath the center-console insert of the vehicle. Troopers testified Seay admitted possession of both items.
Defense objected at trial to admission of the pills under MRE 401 (relevance), but did not object under MRE 404(b) or MRE 403; defense also did not object during closing to prosecutor’s remarks linking the pills and gun.
On cross-examination the prosecutor questioned Seay about prior convictions; a misunderstanding occurred where Seay initially appeared to deny they were "crimes of dishonesty," later clarified on direct and cross-exam.
Seay appealed arguing (1) admission of the pills and prosecutor’s discussion of them violated MRE 404(b) and MRE 403 and denied a fair trial, and (2) prosecutorial misconduct by accusing Seay of lying about his convictions. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of pills as other-acts (MRE 404(b))	Pills were admissible to corroborate troopers’ testimony and show knowledge	Admission was impermissible propensity evidence and prejudicial	Unpreserved; even if other-acts, admissible for nonpropensity purpose (knowledge); no plain error affecting substantial rights; affirmed
Admission of pills under MRE 403 (unfair prejudice)	Probative value (same location; admission) outweighed any prejudice	Pills were unfairly prejudicial and could unduly influence jury	Evidence not unfairly prejudicial; marginal mention and corroborative value made admission proper; no plain error
Closing argument linking pills and gun	Prosecutor reasonably argued inferences from evidence	Remarks suggested impermissible character attack and amplified alleged confession without audio	No preserved objection; remarks allowable argument of evidence and inferences; not outcome-determinative; affirmed
Prosecutorial misconduct re: accusing defendant of lying about priors	Prosecutor reasonably inferred dishonesty from cross-examination exchange	Misstatement improperly accused Seay of lying and could prejudice jury	Court found some error but no prejudice or outcome-determinative effect given other evidence; affirmed

People v. Douglas, 496 Mich. 557 (Michigan 2014) (objection preservation rule for evidentiary issues)
People v. Knox, 469 Mich. 502 (Michigan 2003) (preservation and plain-error review for evidentiary objections)
People v. Kowalski, 489 Mich. 488 (Michigan 2011) (plain-error framework)
People v. Putman, 309 Mich. App. 240 (Mich. Ct. App. 2015) (prejudice requirement under plain-error review)
People v. Bass, 317 Mich. App. 241 (Mich. Ct. App. 2016) (MRE 403 unfair prejudice analysis)
People v. Kanaan, 278 Mich. App. 594 (Mich. Ct. App. 2008) (trial court credibility determinations not disturbed on appeal)
People v. Brown, 279 Mich. App. 116 (Mich. Ct. App. 2008) (standard for prosecutorial misconduct review)
People v. Gaines, 306 Mich. App. 289 (Mich. Ct. App. 2014) (plain-error review for unpreserved prosecutorial misconduct)
People v. Bennett, 290 Mich. App. 465 (Mich. Ct. App. 2010) (closing-argument remarks reviewed in context)
People v. Seals, 285 Mich. App. 1 (Mich. Ct. App. 2009) (consider prosecution comments in light of admitted evidence)
People v. Fyda, 288 Mich. App. 446 (Mich. Ct. App. 2010) (prosecution has broad latitude in argument)
People v. Schumacher, 276 Mich. App. 165 (Mich. Ct. App. 2007) (prosecutor may argue reasonable inferences from evidence)