COA 371610 PEOPLE OF MI V MICHAEL CORNEL PHILLIPS-EDWARDS Opinion - Per Curiam - Unpublished 2/12/2026

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
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S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
PEOPLE OF THE STATE OF MICHIGAN,
Plaintiff-Appellee,
UNPUBLISHED
February 12, 2026
9:54 AM
v No. 371610
Wayne Circuit Court
MICHAEL CORNEL PHILLIPS-EDWARDS, LC No. 21-006295-01-FC
Defendant-Appellant.
Before: CAMERON, P.J., and M. J. KELLY and YOUNG, JJ.
PER CURIAM.
Defendant appeals as of right his conviction of first-degree premeditated murder,
MCL 750.316(1)(a). We affirm.
I. FACTUAL AND PROCEDURAL BACKGROUND
On July 2, 2020, the victim was shot and killed outside his hotel room. Shortly thereafter,
Detroit Police Officers responded to a report of a shooting victim at a gas station near the hotel,
where they encountered defendant, who was injured. Later that day, the victim’s body was
discovered in front of his hotel room. Surveillance footage from the hotel on the night of the
murder showed defendant and his codefendant, Spencer Weston, sitting in the parking lot in
Weston’s vehicle for an extended period of time. Defendant, wearing what appears to be a face
mask, exits Weston’s vehicle, and gets into his own vehicle, parking it next to Weston’s vehicle.
Shortly thereafter, the victim exited his hotel room and entered the front-passenger seat of
defendant’s vehicle. Weston, also wearing a face mask, then exited his vehicle and opened the
victim’s door, blocking him in on the passenger’s side. Defendant and the victim exited the
vehicle, and, as defendant headed toward the victim’s hotel room, the victim and Weston followed,
with Weston trailing closely behind the victim’s back, appearing to guide him. The door to
victim’s hotel room was hidden from camera view, but, from the available footage, it appears that
the victim was shot about nine seconds after the men were out of sight. Defendant and Weston
then fled the scene. Surveillance footage covering the side of the gas station showed defendant
hiding a backpack and tossing an object out of the camera’s view shortly after the shooting. About
seven minutes later, defendant returned to the side of the gas station and is seen speaking to an

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unidentified male while pointing at the area where he had concealed the backpack. After both men
leave, the unidentified male returned to retrieve the object and backpack.
Defendant and Weston were each charged with first-degree premeditated murder and
felony-murder, MCL 750.316(1)(b). At trial, the detective who reviewed the surveillance footage
was asked about the object defendant tossed depicted in the gas station footage. Over defendant’s
objection, the detective testified that he believed the object was a handgun. During closing
arguments, the prosecutor explained to the jury that defendant was charged under an aiding-and-
abetting theory. The trial court instructed the jury on aiding and abetting, and the jury convicted
defendant as noted. This appeal followed.
II. IMPROPER TESTIMONY
Defendant argues the detective’s testimony identifying the object he discarded in the gas
station surveillance footage should not have been admitted at trial because his testimony invaded
the province of the jury and substantially impacted his right to a fair trial. We disagree.
A. STANDARD OF REVIEW
A trial court’s decision to admit evidence is reviewed for an abuse of discretion. People v
Gursky, 486 Mich 596, 606; 786 NW2d 579 (2010). A trial court abuses its discretion by selecting
an outcome that falls outside the range of reasonable and principled outcomes. People v Butka,
514 Mich 366, 376; 22 NW3d 429 (2024).
B. ANALYSIS
MRE 701,1 which permits the admission of lay opinion testimony, states:
If the witness is not testifying as an expert, the witness’ testimony in the form of
opinions or inferences is limited to those opinions or inferences which are (a)
rationally based on the perception of the witness and (b) helpful to a clear
understanding of the witness’ testimony or the determination of a fact in issue.
Such testimony must not “invade the province of the jury.” People v Fomby, 300 Mich App 46,
52; 831 NW2d 887 (2013). Lay opinion testimony does not invade the province of the jury when
the witness is “in the best position to identify the individuals” in question, provided that the witness
does not express an opinion on the defendant’s guilt or innocence. Id. at 52-53.
Here, the detective testified that, “[b]ased off [his] years in law enforcement[,] it appeared
that [defendant] removed a handgun from the right side of his waistband and tossed it to the rear
of the [gas station].” Defendant claims it is “entirely unclear” from the surveillance footage
whether he had a weapon. But defendant’s assessment of the evidence is not the issue. Here, the
1 The Michigan Rules of Evidence were amended on September 20, 2023, effective January 1,
2024. We rely on the version of MRE 701 in effect at the time of trial.

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detective had 27 years of experience working as a Detroit Police Officer, including 11 years as a
homicide detective. Considering this experience, he was in a better position than the average juror
to recognize a firearm. Id. Because the detective’s testimony was rationally based on his
observations of the surveillance footage, and was helpful to determine what object defendant
tossed, his testimony was admissible under MRE 701. Moreover, because the testimony involved
the identification of an object, and the detective never offered an opinion regarding defendant’s
guilt or innocence, his testimony did not invade the province of the jury. Fomby, 300 Mich App
at 53. Accordingly, the trial court’s decision to admit the detective’s testimony was not an abuse
of discretion.
The detective testified that he believed defendant had removed a handgun from the right
side of his waistband and tossed it to the back of the gas station. Such an inference is rationally
based on the perception of the detective in viewing the footage, which shows defendant reach
toward his waistband and throw something, and is helpful to provide the jury with an understanding
of his testimony. MRE 701. Thus, the testimony was admissible.
III. SUFFICIENCY OF THE EVIDENCE
Defendant also argues there was insufficient evidence to sustain his conviction. We
disagree.
A. STANDARD OF REVIEW
“We review de novo a challenge to the sufficiency of the evidence.” People v Baskerville,
333 Mich App 276, 282; 963 NW2d 620 (2020). We review evidence “in a light most favorable
to the prosecutor to determine whether any trier of fact could find the essential elements of the
crime were proven beyond a reasonable doubt.” Id. (quotation marks and citation omitted). “The
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 Bailey, 310 Mich App 703,
713; 873 NW2d 855 (2015) (quotation marks and citation omitted). Circumstantial evidence, “and
reasonable inferences arising from that evidence[,] can constitute satisfactory proof of the elements
of a crime.” Id. (quotation marks and citations omitted).
B. ANALYSIS
To support a conviction of premeditated murder under MCL 750.316(1)(a), the prosecutor
must prove, beyond a reasonable doubt: “(1) the intentional killing of a human (2) with
premeditation and deliberation.” People v Oros, 502 Mich 229, 240; 917 NW2d 559 (2018). The
offense involves “murder perpetrated by means of . . . lying in wait, or any other willful, deliberate,
and premeditated killing.” Id., citing MCL 750.316(1)(a) (quotation marks and brackets omitted).
“[T]o premeditate is to think about beforehand; to deliberate is to measure and evaluate the major
facets of a choice or problem.” Oros, 502 Mich at 240 (quotation marks and citation omitted).
“Premeditation may be established through evidence of (1) the prior relationship of the parties, (2)
the defendant’s actions before the killing, (3) the circumstances of the killing itself, and (4) the
defendant’s conduct after the homicide.” People v Unger, 278 Mich App 210, 229; 749 NW2d
272 (2008).

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All four considerations support the jury’s finding of premeditation in this case. First,
testimony from defendant’s friend and the victim’s mother demonstrated that defendant had a close
prior relationship with the victim. Second, surveillance footage from the hotel shows defendant
and Weston waiting in the parking lot for an extended period of time before the victim came out.
They arranged their vehicles to be close to one another, and defendant admitted to calling the
victim when he arrived. Defendant also admitted to police that he was at the hotel the night of the
shooting, and, on appeal, concedes that he was in the hotel parking lot with Weston the night of
the shooting. Third, Weston and defendant led the victim behind a stairwell wall where he was
then shot off-camera about nine seconds later. At trial, the medical examiner testified that the
victim was shot twice; one of the gunshot wounds to the victim’s back was described as a contact
wound, meaning that the barrel of the gun was pressed up against the victim’s body. Finally, after
the shooting, defendant and Weston fled the scene. Surveillance footage from the gas station
shows defendant hiding a backpack and discarding an object from his waistband, which the
detective believed was a handgun. Defendant later showed the backpack to an unknown male,
before returning to the front of the gas station. The unknown male retrieved the backpack, and left
with it. Defendant, however, lied to first responders by telling them that he gave his sister the
backpack. All these actions, viewed in a light most favorable to the prosecutor, Baskerville, 333
Mich App at 282, support the jury’s finding that defendant thought about killing the victim
beforehand, Oros, 502 Mich at 240.2
Affirmed.
/s/ Thomas C. Cameron
/s/ Michael J. Kelly
/s/ Adrienne N. Young
2 Despite being convicted under an aiding-and-abetting theory, on appeal, defendant only devotes a
brief paragraph to aiding and abetting, and does not include any support for his argument. Because
defendant has provided no argument or citation to relevant authority, this argument is abandoned. See
People v McPherson, 263 Mich App 124, 136; 687 NW2d 370 (2004) (“The failure to brief the merits
of an allegation of error constitutes an abandonment of the issue.”); see also People v Kelly, 231 Mich
App 627, 640-641; 588 NW2d 480 (1998) (“An appellant may not merely announce his position and
leave it to this Court to discover and rationalize the basis for his claims, nor may he give only cursory
treatment with little or no citation of supporting authority.”).

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