People of Michigan v. Steven Michael Brooks

Michigan Court of Appeals·Decided August 10, 2026·No. 374635·Unpublished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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED August 10, 2026

Plaintiff-Appellee, 3:15 PM

v No. 374635 Van Buren Circuit Court

STEVEN MICHAEL BROOKS, LC No. 2022-024127-FH

Defendant-Appellant.

Before: BOONSTRA, P.J., and YOUNG and KOROBKIN, JJ.

PER CURIAM.

Defendant, Steven Michael Brooks, appeals by right convictions of third-degree fleeing and eluding, MCL 257.602a(3)(a), and domestic violence, MCL 750.81(2), following a bench trial. Defendant contends that the evidence was insufficient to support either conviction. For the reasons below, we disagree and therefore affirm.

I. BACKGROUND AND FACTS

Trial testimony established that on June 21, 2022, Paw Paw Police Officers Matt Johnson and Richard Gibbs responded in uniform and a fully-marked patrol car to a dispute on East Berrien Street. Sally Babcock-Gamber had called the police because defendant and his sister, Rebecca Brooks,1 whose uncle lived next door, were on her property and filming her family in connection with allegations about stolen property. Officer Johnson spoke to both groups of neighbors separately. Defendant responded by becoming verbally aggressive and yelling profanities. He also tried to stop Rebecca from speaking to the police.

After speaking with the Brookses and giving them a warning for disturbing the peace, Officer Johnson returned to the Babcocks’ house to warn them about disturbing the peace as well. During this time, Officer Gibbs positioned himself outside so that he could see the Babcocks and the Brookses. Rebecca testified that both she and defendant were very upset. Officer Gibbs

1 Because Rebecca Brooks shares the same last name as defendant, we refer to her by her first name.

recalled that defendant was “highly agitated” and that he saw defendant shove Rebecca with two hands to her shoulders. Defendant, at trial, denied shoving Rebecca; he testified that he and Rebecca had been bickering when he tried to calm his sister down by giving her a hug and that she was the one who pushed him away. For her part, Rebecca echoed defendant’s account by testifying that defendant tried to hug her and she responded, “don’t f****** touch me, just leave.”

The cruiser’s dashcam video, which was admitted at trial, captured audio and some video from the incident. After Officer Gibbs saw defendant’s altercation with Rebecca off-camera, Officer Gibbs told Officer Johnson “let’s go,” and both officers ran toward the Brooks residence as defendant was getting into his vehicle. Rebecca stepped in between Officer Johnson and defendant and told the officers that defendant did not hit her. Rebecca grabbed onto Officer Johnson as he yelled at defendant to stop. Defendant accelerated backwards out of the driveway and reversed down East Berrien Street, away from the Babcock residence and from where the officers’ patrol car was parked. According to Officer Johnson and as reflected in the dashcam video, defendant then reversed into another driveway at a high rate of speed, put the car in drive, and drove forward, turning onto a side street.

At trial, defendant acknowledged that he was driving the white Chevrolet Trailblazer that appears in the video but testified that he was not aware of the officer’s verbal command to stop because he did not hear any commands. Rebecca testified that the window of the defendant’s vehicle was up because the vehicle had electrical issues and the window often did not work. However, Officer Johnson testified that the window was down. Defendant testified that he drove backwards down the street to avoid passing the neighbor’s house, and that he did not see the patrol car parked there.

Officer Johnson testified that driving down the street backwards is a violation of traffic laws. Officer Johnson also testified that he did not know how fast defendant was driving because he never timed him and could not recall whether he ran any stop lights. While driving, defendant did not pull over his vehicle in response to the patrol vehicle’s lights and sirens, which he denied seeing or hearing. The officers ultimately terminated their pursuit because the Paw Paw Police Department does not allow lengthy pursuits of a vehicle for misdemeanor offenses.

Following trial, the trial court made findings of fact in accordance with MCR 6.403 and found defendant guilty on both charged counts. Defendant now appeals.

II. STANDARD OF REVIEW

“A claim that the evidence was insufficient to convict a defendant invokes that defendant’s constitutional right to due process of law.” People v Lane, 308 Mich App 38, 57; 862 NW2d 446 (2014). This Court reviews a challenge to the sufficiency of evidence supporting a conviction de novo. People v Parkinson, 348 Mich App 565, 573; 19 NW3d 174 (2023). We must review the evidence “in the light most favorable to the prosecution and determine whether a rational trier of fact could have found that the essential elements of the crime were proven beyond a reasonable doubt.” People v Kanaan, 278 Mich App 594, 618; 751 NW2d 57 (2008). “Circumstantial evidence and reasonable inferences arising from the evidence can constitute satisfactory proof of the elements of a crime.” People v Nowack, 462 Mich 392, 400; 614 NW2d 78 (2000). When evaluating the sufficiency of the evidence, “[t]he standard of review is deferential, and this Court

is required to draw all reasonable inferences and make credibility choices” in support of the verdict. People v Powell, 278 Mich App 318, 320; 750 NW2d 607 (2008) (quotation marks and citation omitted). “[R]eversing a guilty verdict on the basis that there was insufficient evidence is a high bar to overcome.” People v Prude, 513 Mich 377, 384-385; 15 NW3d 249 (2024).

“In a bench trial, factual findings are sufficient as long as it appears that the trial court was aware of the issues in the case and correctly applied the law.” Parkinson, 348 Mich App at 574 (cleaned up). We review the interpretation and application of statutes de novo. Id.

III. ANALYSIS

A. FLEEING AND ELUDING

Defendant first contends that he was denied his due-process right to a fair trial because there was insufficient evidence to convict him of third-degree fleeing and eluding. We disagree.

MCL 257.602a(1) provides as follows:

A driver of a motor vehicle who is given by hand, voice, emergency light, or siren a visual or audible signal by a police or conservation officer, acting in the lawful performance of his or her duty, directing the driver to bring his or her motor vehicle to a stop shall not willfully fail to obey that direction by increasing the speed of the motor vehicle, extinguishing the lights of the motor vehicle, or otherwise attempting to flee or elude the officer. This subsection does not apply unless the police or conservation officer giving the signal is in uniform and the officer’s vehicle is identified as an official police or department of natural resources vehicle.

And MCL 257.602a(3) provides, in pertinent part:

[A]n individual who violates [MCL 257.602a(1)] is guilty of third-degree fleeing and eluding, a felony punishable by imprisonment for not more than 5 years or a fine of not more than $1,000.00, or both, if . . . the following circumstances apply:

* * *

(b) A portion of the violation occurred in an area where the speed limit is 35 miles an hour or less, whether that speed limit is posted or imposed as a matter of law.

Thus, to obtain a conviction of third-degree fleeing and eluding under MCL 257.602a(3), the prosecution must prove the following six elements:

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Related

People v. Powell
750 N.W.2d 607 (Michigan Court of Appeals, 2008)
People v. Terry
553 N.W.2d 23 (Michigan Court of Appeals, 1996)
People v. Medlyn
544 N.W.2d 759 (Michigan Court of Appeals, 1996)
People v. Kanaan
751 N.W.2d 57 (Michigan Court of Appeals, 2008)
People v. Grayer
599 N.W.2d 527 (Michigan Court of Appeals, 1999)
People v. Nowack
614 N.W.2d 78 (Michigan Supreme Court, 2000)
People v. Lane
862 N.W.2d 446 (Michigan Court of Appeals, 2014)