visibly impaired, third offense. On September 27, 2011 (four days after trial), the prosecution filed a second amended felony information to increase defendant’s habitual-offender level back to fourth-offense status. Defendant did not object to this amendment, and on December 5, 2011, the trial court sentenced him as a fourth-offense habitual offender. II. ANALYSIS Defendant’s only argument on appeal is that the trial court erred by sentencing him as a fourth-offense habitual offender. Defendant did not raise this issue before the trial court; therefore, our review is for plain error. See People v Carines, 460 Mich 750, 763-764; 597 NW2d 130 (1999). To avoid issue forfeiture under the plain-error rule, defendant must prove the following: ( 69-470; 117 S Ct 1544; 137 L Ed 2d 718 (1997) (<HOLDING>). MCL 769.13 governs the procedure for seeking
recognizing that plain error analysis requires 1 error 2 that is plain 3 that affects defendants substantial rights and 4 that seriously affects fairness integrity or public reputation of judicial proceedings holding that the closure of a courtroom during jury selection a structural error did not seriously affect the fairness integrity or public reputation of the judicial proceedings holding that even if a defendant is able to show that there was a plain error that affected his substantial rights a court of appeals is not required to reverse a conviction unless it finds that the error seriously affected the fairness integrity or public reputation of judicial proceedings holding that plain error will be identified only if 1 there is error 2 that is clear or obvious rather than subject to reasonable dispute 3 that affects defendants substantial rights and 4 that seriously impugns fairness integrity or public reputation of judicial proceedings holding that a plain error did not seriously affect the fairness integrity or public reputation of the judicial proceedings even though the error was assumed to have affected substantial rights