People of Michigan v. Terrance D Woodruff, 366550

Terrance D. Woodruff was charged with possession with intent to deliver over 50 grams but less than 450 grams of heroin or fentanyl, following an arrest at a Detroit Greyhound bus station.
Michigan State Police Trooper Benjamin Sonstrom, using a canine, searched Woodruff’s bag after finding active warrants and observing suspicious behavior; the search produced 116.5 grams of narcotics.
Woodruff moved to suppress the drug evidence, arguing an unreasonable search and seizure, and an evidentiary hearing was scheduled.
On the hearing date, Trooper Sonstrom was absent due to an emergency requiring his canine handling skills at a SWAT operation; the prosecutor explained his absence and indicated the inability to proceed without him.
The trial court refused to adjourn, granted Woodruff’s motions to suppress and dismiss, and dismissed the case without prejudice; the prosecution appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was it an abuse of discretion to deny an adjournment when a key witness was unavailable due to emergency duties?	Prosecution argued that good cause existed for adjournment due to sudden emergency, diligent subpoena efforts, and the necessity of Trooper Sonstrom’s testimony for justice.	Woodruff argued no formal adjournment request was made and he would be prejudiced by delay, seeking immediate suppression and dismissal.	Yes; the trial court abused its discretion. Good cause for adjournment existed, and suppression/dismissal was improper. Case remanded for further proceedings.

People v. Jackson, 467 Mich 272 (Mich. 2002) (standard for reviewing denials of adjournments; diligent effort to produce subpoenaed witness required)
People v. Seewald, 499 Mich 111 (Mich. 2016) (defines abuse of discretion as decisions outside a range of reasonable and principled outcomes)
People v. Grace, 258 Mich App 274 (Mich. Ct. App. 2003) (discusses procedure for adjournment requests due to absent witnesses)
People v. Buie, 491 Mich 294 (Mich. 2012) (defines "good cause" for adjournments)