Sufficiency of the evidence for an assaulting, resisting, or obstructing a police officer conviction; MCL 750.81d(1); Great weight of the evidence; Admission of the arrest warrants for defendant’s son & daughter; Description of the warrants as “felony warrants”; Testimony that defendant was an “American National”; Admissions of a party opponent under MRE 801(d)(2)(A); Relevance; Ineffective assistance of counsel

The court held that “the actions of defendant and her husband ‘basically being human blockades’ constituted violations of MCL 750.81d(1) and” supported her convictions of assaulting, resisting, or obstructing an officer. Further, (1) the arrest warrants for her son and daughter were properly admitted at her trial, (2) there was no error in allowing the prosecution to refer to them as felony warrants, and (3) the trial court properly deemed statements she and her husband made in police body-cam footage about “being ‘American National’ or American Nationals” relevant. Finally, the court rejected her ineffective assistance of counsel claims. The case arose after defendant physically blocked “officers to keep them away from her children, so they both were able to escape arrest.” She asserted “that, at her advanced age, she could not block the officers, but all the evidence in the record” showed that she stood in their way to help her two children escape arrest. A deputy “commented that he ‘had to physically move [defendant] backwards’ to get past her as she blocked the officers, and when he saw defendant’s daughter ‘at one point inside the house,’ the officers ‘were blocked again by defendant and’” another individual (T), which enabled “defendant’s daughter ‘to exit out the back door with [T].’” The court concluded that “defendant’s efforts to block the officers from performing their duties enabled [her] daughter to evade arrest on a valid warrant. The jury apparently believed the officers’ testimony that defendant did not comply with their commands or allow them to perform their jobs. At no point in the trial court or on appeal has [she] asserted that the police officers were not lawfully engaged in the exercise of their official duties or that she did not know or have reason to know that they were” officers. The court further concluded that “the arrest warrants provided significant evidence that the officers acted lawfully when they entered the house to execute the arrest warrants for defendant’s son and daughter.” As to the American Nationals statements, the prosecution had to prove that she “purposefully or voluntarily performed the wrongful act.” The court found this “evidence was relevant because it made it more likely that defendant intentionally stood in the hallway to obstruct the officers’ attempts to arrest [her] son and daughter because she believed the law did not apply to her.” Affirmed.