Background
Doug Arthur Wolshlager entered Lincoln Township Hall seeking a Freedom of Information Act form. Witnesses testified that he yelled, used vulgar language, refused requests to move away from the payment counter, threatened employees and their families, and poked the building official with a pen. Multiple employees felt uncomfortable and called the police.
After 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 executing a written waiver of counsel, Wolshlager was convicted of disturbing the peace and resisting or obstructing Springer-Grounds, but acquitted of the obstruction count involving Officer Joshua Quandt.
Wolshlager challenged the sufficiency of the evidence and argued that the trial court violated MCR 6.005(B) by failing to refer him to the appointing authority for indigency screening after he expressed interest in public-defender assistance to obtain an expert on diabetes and 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 evidence permitted a rational jury to find that Wolshlager intentionally disrupted the previously quiet township hall and interfered with employees’ duties through his yelling, vulgarities, threats, physical contact with the building official, and conduct that caused employees to summon assistance and call police. The conduct went beyond merely stating a position, expressing ideas, or offering an opinion.
The court also found sufficient evidence of resisting or obstructing Springer-Grounds. Body-camera footage showed that the officer told Wolshlager “you gotta go” after explaining that township personnel wanted him removed. The court treated that statement as a command, found no basis in the record to deem it unlawful, and concluded that Wolshlager knowingly failed to comply. Because that failure independently supported the conviction, the court did not decide whether the subsequent warrantless arrest was lawful.
Finally, the court held that the trial court complied with MCR 6.005(B) on this record. The trial judge identified Chief Public Defender Scott Sanford as the relevant appointing authority, directed Wolshlager to contact him, explained that the public defender’s office would screen him for eligibility, and emphasized the importance of obtaining its assistance if he wanted to present expert testimony. Wolshlager later continued to insist on self-representation and proceeded to trial without counsel.
Key Takeaways
- A jury could find a disturbance under MCL 750.170 where aggressive conduct disrupted a quiet public office and diverted employees from their duties.
- A knowing failure to obey the officer’s lawful command to leave supported the obstruction conviction independently of whether Wolshlager resisted a lawful arrest.
- The trial court’s specific directions to the identified public-defender authority and explanation of the screening process satisfied MCR 6.005(B) on the record presented.
Why It Matters
The unpublished decision illustrates how testimony about workplace disruption, employee fear, and diverted duties can establish disturbing the peace in a public building. It also shows that body-camera evidence and the context of an officer’s words may establish both a lawful command and a defendant’s knowing refusal to comply.
The opinion further underscores the importance of a clear record when a self-represented defendant later expresses interest in appointed counsel. Here, the trial court’s identification of the appointing authority and explanation of the indigency-screening process defeated Wolshlager’s claim of noncompliance with MCR 6.005(B).