People of Michigan v. William Michael Badger Jr

CourtMichigan Court of Appeals
DecidedJune 17, 2026
Docket371777
StatusUnpublished

This text of People of Michigan v. William Michael Badger Jr (People of Michigan v. William Michael Badger Jr) 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. William Michael Badger Jr, (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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 17, 2026 Plaintiff-Appellee, 2:58 PM

v No. 371777 Lenawee Circuit Court WILLIAM MICHAEL BADGER, JR., LC No. 2021-020463-FH

Defendant-Appellant.

Before: BAZZI, P.J., and RICK and MALDONADO, JJ.

PER CURIAM.

Defendant, William Badger, Jr., appeals by right his jury conviction of operating while intoxicated causing death, MCL 257.625, and reckless driving causing death, MCL 257.626. The trial court sentenced defendant to serve 54 months to 15 years in prison for each conviction, with the sentences to run concurrently and with credit for 170 days served in jail. Defendant’s appellate counsel argues that there was insufficient evidence supporting the “willful and wanton” element of the reckless driving conviction, that defendant’s trial counsel’s assistance was ineffective when he failed to object to the prosecutor’s repeated references to defendant’s refusal to submit to a blood draw, and that defendant’s within-guidelines sentences are unreasonable.

Defendant also filed a Standard 4 supplemental brief in propria persona in accordance with Administrative Order 2004-6. In his Standard 4 brief, defendant claims that his trial counsel was ineffective when he advised defendant to decline the prosecutor’s plea offer. Defendant further argues that his convictions are void because he was charged on information without a grand jury indictment, in violation of his Fifth and Fourteenth Amendment rights to due process. We affirm.

I. BACKGROUND

This case arises from a fatal car accident in May 2021, in which defendant was driving his neighbor’s convertible, lost control, and killed his passenger, David Campell. David and his wife, Karen Campbell, lived on defendant’s street, and defendant would often visit them. On the day of the accident, defendant visited the Campbells, and he and David each had a glass of Jameson whiskey. Karen showed defendant her new car, a 2003 Lexus convertible. It was a clear, sunny

-1- day, and defendant offered to wax Karen’s car, commenting that if it was his, he would be “driving the shit out of it today.” While defendant waxed Karen’s car, David prepared defendant a second drink, which Karen kicked over. After defendant finished waxing the car, David prepared defendant a third drink, which defendant kicked over. Karen was not sure if defendant consumed any of the second or third drinks. Nevertheless, at that point, the whiskey was gone, and defendant offered to drive to the liquor store to buy more. Karen knew that defendant admired her car, so she suggested that defendant drive it to the liquor store, with David riding along. On defendant and David’s drive back from the liquor store, defendant lost control of the convertible. The car flipped over and landed in a ditch. David broke his neck and died at the scene. Defendant was transported by ambulance to the Toledo Hospital in Ohio.1

When defendant arrived at the hospital, the medical staff drew his blood and screened it for drugs. Lenawee County Sheriff’s Deputy William Warner interviewed defendant at the hospital, which was captured on body camera footage. In the recorded interview, defendant admitted to driving 65 miles per hour and to drinking a shot of whiskey before driving. He declined Deputy Warner’s request for a blood draw, stating, “No disrespect, I plead the fifth on that.” Law enforcement then subpoenaed the results of the hospital’s blood test, which revealed that defendant’s ethanol level, or blood alcohol content (BAC), was 0.18 grams of alcohol per 100 milliliters of blood.2

Defendant was charged as previously noted and pleaded not guilty. He also declined the prosecutor’s plea offer to plead guilty to either one of the charges and serve one year in jail; so, the case proceeded to a jury trial. Prior to trial, defense counsel attempted to exclude the results of the BAC test unless the prosecutor presented an expert witness to testify about the result’s validity and reliability. Following an evidentiary hearing, the trial court determined that the BAC test results were admissible under MCL 257.625a(6)(e)3 and that expert testimony was not necessary. At trial, defense counsel again attempted to exclude the results of the hospital’s BAC test results on the grounds that the prosecutor failed to lay a proper foundation. The trial court overruled defendant’s objection and admitted the test results.

1 This incident took place in Lenawee County, Michigan, which shares a border with Ohio. 2 The unlawful BAC level is 0.08. MCL 257.625(1)(b). 3 MCL 257.625a(6)(e) states in relevant part: If, after an accident, the driver of a vehicle involved in the accident is transported to a medical facility and a sample of the driver's blood is withdrawn at that time for medical treatment, the results of a chemical analysis of that sample are admissible in any civil or criminal proceeding to show the amount of alcohol . . . in the person's blood at the time alleged, regardless of whether the person had been offered or had refused a chemical test. The medical facility or person performing the chemical analysis shall disclose the results of the analysis to a prosecuting attorney who requests the results for use in a criminal prosecution as provided in this subdivision.

-2- Throughout the four-day trial, the prosecutor’s witnesses included law enforcement; emergency responders, who treated defendant at the crash site; hospital workers, who treated defendant at the hospital; witnesses to the crash; and crash site investigators. Witnesses of defendant’s behavior before the crash testified that he drank alcohol and that he appeared to be drunk. Witnesses of the crash itself testified that defendant was driving excessively fast and that he neglected to stop at a clearly marked stop sign. Witnesses who interacted with defendant after the crash testified that defendant admitted to drinking alcohol and driving in excess of the speed limit, which was set at 55 miles per hour.

The jury convicted defendant of both charges, and the trial court sentenced him as described earlier. This appeal followed.

II. RECKLESS DRIVING CAUSING DEATH

Defendant argues that the prosecution failed to present sufficient evidence of reckless driving and that if this conviction is reversed, defendant is also entitled to resentencing. We disagree.

We review a challenge to the sufficiency of the evidence by reviewing the evidence de novo “in the light most favorable to the prosecution to determine whether a rational trier of fact could have found that the essential elements of the crime were proved beyond a reasonable doubt.” People v Roper, 286 Mich App 77, 83; 777 NW2d 483 (2009). “But more importantly, ‘[t]he standard of review is deferential: a reviewing court is required to draw all reasonable inferences and make credibility choices in support of the jury verdict.’ ” People v Oros, 502 Mich 229, 239; 917 NW2d 559 (2018), quoting People v Nowack, 462 Mich 392, 400; 614 NW2d 78 (2000). Further, the prosecutor does not have to negate every reasonable theory consistent with innocence—the prosecutor is bound only “to prove the elements of the crime beyond a reasonable doubt” and “in the face of whatever contradictory evidence the defendant may provide.” Nowack, 462 Mich at 400 (quotation marks and citation omitted).

“Due process requires that a prosecutor introduce evidence sufficient to justify a trier of fact to conclude that the defendant is guilty beyond a reasonable doubt.” People v Tombs, 260 Mich App 201, 206-207; 679 NW2d 77 (2003), aff’d 472 Mich 446 (2005).

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People of Michigan v. William Michael Badger Jr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-william-michael-badger-jr-michctapp-2026.