The Michigan Supreme Court affirmed the conviction of Michael G. Carson on multiple felony charges stemming from the theft of approximately $60,000 in cash and valuable property from his neighbor's home in 2019. The court issued its decision July 31, 2025, following oral arguments heard April 10.
Carson was convicted in the Emmet Circuit Court of safebreaking under MCL 750.531, larceny of property valued at $20,000 or more under MCL 750.356(2)(a), receiving or concealing stolen property valued at $20,000 or more under MCL 750.535(2)(a), larceny from a building under MCL 750.360, and accompanying conspiracy charges under MCL 750.157a.
The case originated in August 2019 when victim Don Billings granted Carson and his girlfriend, Brandie DeGroff, access to his house to help him sell items online. Billings later discovered that valuable items were missing from his bedroom and that his safes had been emptied of their contents, which included approximately $60,000 in cash.
Following a police investigation, Carson was arrested and his cell phone was seized by authorities. Police obtained a warrant to search the phone's contents, which revealed incriminating text messages between Carson and DeGroff that proved central to the prosecution's case.
The defense moved before trial to suppress the introduction of evidence obtained from the cell phone search, raising Fourth Amendment concerns about the warrant and search procedures. However, the trial court denied the motion to suppress, allowing the text message evidence to be presented to the jury.
The case highlights several important legal issues in property crime prosecution, particularly regarding the use of digital evidence obtained through cell phone searches. The text messages between Carson and DeGroff apparently provided crucial evidence of their coordination in the theft scheme.
Carson's conviction on multiple felony charges reflects the serious nature of the crimes involved. Safebreaking carries substantial penalties under Michigan law, as does larceny of property valued at $20,000 or more. The conspiracy charges indicate that prosecutors were able to prove Carson worked in coordination with DeGroff to carry out the theft.
The victim, Don Billings, had trusted Carson and DeGroff enough to grant them access to his home to assist with selling items online. This breach of trust likely influenced both the prosecution's approach and the jury's verdict, as the defendants exploited their legitimate access to the property to identify and steal valuable items.
The case involved sophisticated criminal activity, as the defendants not only identified valuable items in Billings' bedroom but also successfully opened multiple safes containing the substantial cash sum. The safebreaking charge suggests the defendants used skills or tools to defeat the security measures Billings had in place to protect his valuables.
The conspiracy charges indicate that Carson and DeGroff planned and coordinated their criminal activity, rather than acting on impulse. The text messages discovered on Carson's phone likely provided evidence of this coordination and planning between the co-conspirators.
Carson's conviction on receiving or concealing stolen property charges suggests that beyond the initial theft, he was also found guilty of subsequent criminal activity involving the stolen items. This charge often applies when defendants attempt to hide, sell, or otherwise dispose of stolen property.
The larceny from a building charge addresses the specific location where the theft occurred. Michigan law treats theft from buildings as a distinct offense, reflecting the additional violation of security and privacy that occurs when defendants unlawfully take property from enclosed structures.
The Michigan Supreme Court's decision to affirm Carson's conviction suggests that the lower courts properly handled both the legal and evidentiary issues in the case. The high court's affirmation indicates that Carson's constitutional rights were not violated during the investigation and prosecution.
The case demonstrates the effectiveness of modern digital forensics in property crime investigations. The text messages recovered from Carson's cell phone provided prosecutors with direct evidence of the defendants' criminal coordination and intent.
Carson now faces substantial prison time given the multiple felony convictions and the significant value of the stolen property. Michigan's sentencing guidelines for these offenses, particularly when involving amounts exceeding $20,000, carry lengthy potential prison terms.
The decision may influence future cases involving similar fact patterns, particularly regarding the use of cell phone evidence in property crime prosecutions and the application of conspiracy charges in coordinated theft schemes.
For property owners, the case underscores the importance of being cautious about granting access to valuable items and securing property even from individuals who may initially appear trustworthy. The case also demonstrates law enforcement's ability to use digital evidence to build strong cases against defendants who attempt to coordinate criminal activity through electronic communications.