Background
Doug Arthur Wolshlager entered the Lincoln Township Hall seeking a Freedom of Information Act form. Witnesses testified that he yelled vulgarities at employees, refused requests to move or leave, threatened employees and their families, poked the building official with a pen, and disrupted the previously quiet workplace. Multiple employees called the police.
When officers arrived, Officer Wesley Springer-Grounds told Wolshlager that township employees wanted him removed and that he had to leave. Wolshlager refused, pulled his arm away when the officer grasped it, and was arrested. Representing himself at trial after signing a written waiver of counsel, Wolshlager was convicted of disturbing the peace and resisting or obstructing Springer-Grounds, but acquitted of resisting or obstructing the second officer.
On appeal, Wolshlager challenged the sufficiency of the evidence supporting both convictions. He also argued that the trial court violated Michigan Court Rule 6.005(B) by failing to refer him to the appointing authority for indigency screening after he expressed interest in obtaining public-defender assistance to secure an expert witness concerning the behavioral effects of low blood sugar.
The Court’s Holding
The Court of Appeals held that sufficient evidence supported the disturbing-the-peace conviction. Viewed in the prosecution’s favor, the testimony permitted a rational jury to find that Wolshlager intentionally disrupted the township hall’s peace and quiet and interfered with employees’ duties through aggressive yelling, vulgar insults, threats, physical contact, and conduct that caused employees to summon police and seek assistance.
The court also held that sufficient evidence supported the resisting-or-obstructing conviction. The body-camera footage showed that Springer-Grounds gave Wolshlager a command—not merely a request—by explaining that he was being trespassed and telling him, “you gotta go.” Wolshlager expressly refused and remained for more than 30 seconds before the officer touched him, allowing the jury to find a knowing failure to comply with a lawful command. Because that theory independently supported the conviction, the court did not decide whether the later warrantless arrest was lawful.
Finally, the court held that the trial court complied with MCR 6.005(B). The judge identified the chief public defender by name, directed Wolshlager to seek representation from the public defender’s office, and explained that the office would have him complete a form and determine whether he qualified for counsel. The Court of Appeals therefore affirmed the judgment.
Key Takeaways
- A defendant’s aggressive, threatening, and disruptive conduct in a public building can support a disturbing-the-peace conviction when it interrupts employees’ peace or interferes with their duties.
- A clear direction that a person “has to go,” followed by an express refusal to leave, can establish knowing noncompliance with a lawful police command under Michigan’s resisting-or-obstructing statute.
- A trial court complied with MCR 6.005(B) by identifying the appointing authority and directing the self-represented defendant to that authority’s indigency-screening process.
Why It Matters
The decision illustrates that sufficiency review considers the evidence collectively and in the prosecution’s favor. Conduct extending beyond expression—such as threats, physical contact, and interference with public employees’ work—may satisfy Michigan’s disturbing-the-peace statute.
It also clarifies that resisting or obstructing may rest on knowing noncompliance with a lawful command without resolving whether a subsequent arrest was lawful. For right-to-counsel procedure, the opinion treats a specific, on-the-record direction to the designated public defender and an explanation of the screening process as a sufficient referral under MCR 6.005(B).