People of Michigan v. Joshua Leonce Thomas

CourtMichigan Court of Appeals
DecidedMay 19, 2026
Docket372226
StatusUnpublished

This text of People of Michigan v. Joshua Leonce Thomas (People of Michigan v. Joshua Leonce Thomas) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. Joshua Leonce Thomas, (Mich. Ct. App. 2026).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED May 19, 2026 Plaintiff-Appellee, 11:19 AM

v No. 372226 Allegan Circuit Court JOSHUA LEONCE THOMAS, LC No. 2023-026247-FH

Defendant-Appellant.

Before: WALLACE, P.J., and LETICA and FEENEY, JJ.

PER CURIAM.

Defendant appeals as of right his jury trial convictions for: (1) one count of possession with intent to deliver methamphetamine, MCL 333.7401(2)(b)(i);1 (2) one count of felon in possession of a firearm (felon-in-possession), MCL 750.224f; (3) one count of felon in possession of ammunition, MCL 750.224f(7); and (4) three counts of possession of a firearm during the commission of a felony (felony-firearm), MCL 750.227b.2 The trial court sentenced defendant, as a fourth-offense habitual offender, MCL 769.12, to serve: (1) 5 to 40 years, (2) 2 to 10 years, (3) 2 to 10 years, and (4) 2 years in prison, respectively.3 We affirm.

1 Because this was defendant’s second or subsequent offense as to this conviction, his sentence was enhanced pursuant to MCL 333.7413(1). 2 There are two clerical errors on defendant’s judgment of sentence that the trial court should correct: (1) defendant’s possession with intent to deliver methamphetamine conviction is simply listed as “deliver mfg meth”; and (2) the PACC code for defendant’s felon in possession of ammunition conviction is listed as “750.224F6,” but it should be listed as “750.224F7.” 3 Defendant’s felony-firearm sentences were to be served concurrent to one another but consecutive and proceeding to his other sentences.

-1- I. FACTS

This case arises out of an ongoing police investigation regarding the distribution of methamphetamine, resulting in a search warrant. Two controlled purchases between a confidential informant and Amber Consentino, defendant’s then girlfriend, occurred in the days leading up to the search warrant. Both controlled purchases occurred at the residence that defendant and Consentino shared. The confidential informant “had a brief interaction” with defendant at the first controlled purchase and observed defendant lying on the master bed during the second controlled purchase.

In November 2021, a search warrant was executed at the residence. Defendant was found lying down in the master bedroom where the following relevant items were located: (1) a .45 caliber handgun; (2) $269;4 (3) a nine-millimeter handgun; (4) nine-millimeter ammunition and magazines; (5) nine rounds of .45 caliber ammunition; (6) containers of methamphetamine found in a safe; (7) a 12-gauge shotgun and 21 shotgun shells; (8) scissors with “white crystal residue”; (9) a debit card in defendant’s name; and (10) assorted rifle ammunition, including 50 .357 caliber rounds. Consentino was found in the basement where the following relevant items were located: (1) a loaded nine-millimeter handgun; (2) magazines and nine-millimeter ammunition; and (3) “the bulk of the methamphetamine . . . .” The methamphetamine found totaled about 190 grams and was stored in bags of: (1) 104 grams, (2) 9.2 grams, (3) 8.1 grams, (4) 32 grams, (5) 16.2 grams, and (6) 20 grams.

Defendant was convicted and sentenced, as stated earlier. Defendant moved the trial court for a new trial or an evidentiary hearing, which the trial court denied. Defendant now appeals.

II. MOTION FOR A MISTRIAL

On appeal, defendant first argues that the trial court erred by denying his motion for a mistrial based on a tainted jury pool. We disagree.

A. PRESERVATION AND STANDARD OF REVIEW

Defendant preserved this issue by moving for a mistrial in the trial court. See People v Haynes, 338 Mich App 392; 410; 980 NW2d 66 (2021). “The denial of a motion for a mistrial is reviewed for an abuse of discretion.” People v Alter, 255 Mich App 194, 205; 659 NW2d 667 (2003). “This Court will find an abuse of discretion if the trial court chose an outcome that is outside the range of principled outcomes.” People v Beesley, 337 Mich App 50, 54; 972 NW2d 294 (2021) (quotation marks and citation omitted). “A motion for a mistrial should be granted only for an irregularity that is prejudicial to the rights of the defendant and impairs the defendant’s ability to get a fair trial.” Id. (quotation marks and citation omitted). Accordingly, “for a due process violation to result in reversal of a criminal conviction, a defendant must prove prejudice to his or her defense.” Id. (quotation marks and citation omitted). “And the extent of the prejudice is a critical factor: The moving party must establish that the error complained of is so egregious

4 $100 of the cash found was from the controlled purchase.

-2- that the prejudicial effect can be removed in no other way.” Id. (quotation marks and citation omitted).

B. ANALYSIS

“Determining whether manifest necessity exists to justify the declaration of a mistrial requires a balancing of competing concerns: the defendant’s interest in completing his trial in a single proceeding before a particular tribunal versus the strength of the justification for a mistrial.” People v Beck, 510 Mich 1, 13; 987 NW2d 1 (2022) (quotation marks and citation omitted). “We have stated that a mistrial may only be declared . . . after an on the record consideration and discussion of alternatives with counsel.” Id. (quotation marks and citation omitted). “To declare a mistrial, the trial court must find the facts justifying the mistrial.” Id. “This Court accords considerable deference to a judge’s determination of whether there is manifest necessity justifying declaration of a mistrial.” Id. at 14 (quotation marks and citation omitted). “To ensure that the trial court properly exercised its discretion, the reviewing court must consider the ‘particular facts’ of the case.” Id. “The ultimate question is not whether this Court would have found manifest necessity, but whether the trial court abused its discretion in finding manifest necessity.” Id. (quotation marks and citation omitted).

In this case, during jury selection, a prospective juror expressed his belief that defendant was guilty because he was charged and claimed that defendant looked like he used methamphetamine. Defense counsel and the prosecutor agreed that the juror should be dismissed for cause. As voir dire continued, defense counsel inquired if any other jurors were influenced by the prospective juror’s comments. A second prospective juror admitted that the comments forced him to question his ability to impartially serve on the jury, noting that he believed defendant was guilty of the charges. The trial court informed the juror of defendant’s presumption of innocence and that the burden to prove guilt rested with the prosecution. The second prospective juror admitted he was unsure if he could maintain his impartiality after hearing the comments and was dismissed. The trial court questioned the remaining jurors, asking if the first prospective juror’s comment impacted their ability to be impartial and try the case based on the evidence. The remaining jurors asserted they could remain impartial and could follow the trial court’s instructions.

Once the jury was empaneled, defense counsel moved for a mistrial, arguing that the jury pool was “polluted” by the comments from the prospective jurors. The prosecution made arguments for and against a mistrial but left the decision to the trial court’s discretion.

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Bluebook (online)
People of Michigan v. Joshua Leonce Thomas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-joshua-leonce-thomas-michctapp-2026.