People of Michigan v. Brianna Talynn Lipscomb

Michigan Court of Appeals·Decided July 16, 2026·No. 373953·Unpublished

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED July 16, 2026 Plaintiff-Appellee, 1:31 PM

v No. 373953 Ionia Circuit Court BRIANNA TALYNN LIPSCOMB, also known as LC No. 2024-036468-AR BRIANNA TAYLYNN LIPSCOMB,

Defendant-Appellant.

Before: GADOLA, C.J., and BOONSTRA and CAMERON, JJ.

PER CURIAM.

Defendant appeals by delayed leave granted1 her jury-trial conviction of misdemeanor animal cruelty, MCL 750.50(4)(a). Defendant argues that the trial court erroneously admitted evidence arising from an unconstitutional search and that her 93-day jail sentence was unreasonable and disproportionate. We affirm.

I. PERTINENT FACTS AND PROCEDURAL HISTORY

Defendant lived in the upstairs apartment of a two-unit rental property in Ionia County. Paul Burns lived in the downstairs unit. Burns knew that defendant had a dog because he occasionally saw the dog when defendant tied it up outside or walked with it to retrieve her mail. During the first week of December 2022, Burns heard defendant’s dog moving around upstairs and barking for long periods of time. After days of consistent barking, Burns contacted Ionia Animal Control on December 7, 2022 and reported that the dog had been unattended for six or seven days. Burns also reported the situation to defendant’s landlord, Timothy Todd.

That same day, Animal Control Officer Carly Quinn responded to the apartment building and saw the frantic-looking dog barking through an upstairs window. Officer Quinn knocked on

1 People v Lipscomb, unpublished order of the Court of Appeals, entered August 13, 2025 (Docket No. 373953).

-1- the door of defendant’s apartment but did not receive a response. She left two door hangers on the property to notify the resident that she had been there and stating the time of and reason for the visit. On December 8, 2022, Todd called Officer Quinn, reported his concerns about defendant’s dog, and offered to allow her to enter defendant’s apartment with the maintenance manager, Robert Allen Bliss. Officer Quinn agreed and met Bliss at the apartment. They knocked on the door but received no response. Before entering, Officer Quinn again observed the dog acting frantically in the window, and he detected a strong smell of urine and feces from outside the apartment. Bliss unlocked the door, and the two entered.

Once inside, Officer Quinn and Bliss noticed debris, trash, several puddles of urine, and “approximately 15-20 piles of feces” on the floor. The dog had access to a small amount of dog food but no water. Because she “felt that the conditions were unsanitary and hazardous,” Officer Quinn removed the dog and left a new hanger on the door.

Defendant was charged with misdemeanor animal cruelty. Before trial, defendant moved to suppress any evidence obtained from the allegedly unauthorized search of her home. The prosecution filed a response to the motion, attaching defendant’s lease agreement, which contained the following provision:

Landlord’s Rights Concerning Entry. Landlord reserves the right to repair, show unit, or inspect the Premises upon twenty-four (24) hour notice. In the event of emergencies, the Landlord may enter without notice.

The district court held a suppression hearing, after which it denied defendant’s motion to suppress largely on the basis of this provision.

After a trial, the jury found defendant guilty of misdemeanor animal cruelty, and the district court sentenced defendant as described. Defendant then appealed to the circuit court, arguing that the evidence arising from the allegedly unconstitutional search should have been suppressed and that the district court’s sentence was not proportionate to the seriousness of the circumstances surrounding the offense and the offender.

The circuit court characterized the search issue as one of “third-party consent” and remarked that it was “obvious there was a problem going on in the defendant’s apartment.” It noted that the record showed that “there was an odor coming from” the apartment. The court found that the landlord gave “valid consent” under the emergency exception in the lease. Addressing defendant’s sentence, the court noted that defendant “had a disregard for court orders” and had “admittedly left the state” while out on bond. The court considered “whether rehabilitation was something that was appropriate in this sentence.” On the basis of its review of the record and facts, it found that the district court had “reasonable grounds” for the sentence it imposed. Accordingly, the circuit court affirmed the district court. This appeal followed.

II. SEARCH

Defendant argues that the search of her apartment violated her Fourth Amendment right against unreasonable searches because her landlord lacked the authority to consent to entry. We disagree.

-2- A. STANDARD OF REVIEW

We review for clear error a trial court’s factual findings at a suppression hearing. People v Williams, 472 Mich 308, 313; 696 NW2d 636 (2005). “A finding is clearly erroneous if it leaves this Court with a definite and firm conviction that the trial court made a mistake.” People v Dillon, 296 Mich App 506, 508; 822 NW2d 611 (2012). We review the ultimate decision on a motion to suppress de novo, including the issue of whether a search violated the Fourth Amendment. People v Hyde, 285 Mich App 428, 438; 775 NW2d 833 (2009).

B. ANALYSIS

“Both the United States and Michigan Constitutions guarantee the right against unreasonable searches and seizures.” People v Beuschlein, 245 Mich App 744, 749; 630 NW2d 921 (2001), citing US Const, Am IV; Const 1963, art 1, § 11. Generally, “searches conducted without a warrant are per se unreasonable under the Fourth Amendment unless the police conduct falls under one of the established exceptions to the warrant requirement.” Beuschlein, 245 Mich App at 749.

“Consent searches, when voluntary, are an exception to the warrant requirement.” People v Frederick, 500 Mich 228, 242; 895 NW2d 541 (2017). “The consent exception to the warrant requirement allows a search and seizure when consent is unequivocal, specific, and freely and intelligently given.” People v Frohriep, 247 Mich App 692, 702; 637 NW2d 562 (2001) (quotation marks and citation omitted). Consent to search may also be revoked or limited in scope. Id. at 703. “An owner may not give consent to search premises of a tenant unless contractually provided for.” People v Chism, 390 Mich 104, 134; 211 NW2d 193 (1973).

In this case, Todd had the authority to consent to the search of defendant’s apartment. Defendant executed a lease agreement that gave the landlord2 the right to repair, inspect, or show the apartment “upon twenty-four (24) hour notice” or to enter without notice “[i]n the event of emergencies.” The prosecution does not dispute that defendant did not receive notice, so Todd would only have the right to enter the property if an “emergency” existed that would grant him a right of entry.

The word “emergencies” was not defined in the lease. Absent a specific definition, words in a contract are assigned “their ordinary and plain meaning if such would be apparent to a reader of the instrument.” Auto Owners Ins Co v Seils, 210 Mich App 132, 145; 871 NW2d 530 (2015) (quotation marks and citation omitted). We may consult a dictionary to ascertain the plain and ordinary meaning. Id. The word “emergency” is generally defined as “an unforeseen combination of circumstances or the resulting state that calls for immediate action” or “an urgent need for assistance or relief.” Merriam-Webster’s Collegiate Dictionary (11th ed.).

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Related

People v. Williams
696 N.W.2d 636 (Michigan Supreme Court, 2005)
People v. Beuschlein
630 N.W.2d 921 (Michigan Court of Appeals, 2001)
People v. Frohriep
637 N.W.2d 562 (Michigan Court of Appeals, 2001)
People v. Hyde
775 N.W.2d 833 (Michigan Court of Appeals, 2009)
People v. Chism
211 N.W.2d 193 (Michigan Supreme Court, 1973)
Haupt v. Kerr Manufacturing Co.
532 N.W.2d 859 (Michigan Court of Appeals, 1995)
People v. Dillon
822 N.W.2d 611 (Michigan Court of Appeals, 2012)