Michigan Court Explains Weighing the Relevance of Evidence in Criminal Trials

The Michigan Rules of Evidence dictate what evidence the state is permitted to use against a defendant at trial. Among other things, it must be relevant. Additionally, evidence that passes the relevance threshold may be deemed inadmissible if it is overly prejudicial. In a recent Michigan matter in which a defendant appealed his murder conviction, a court explained how relevancy and prejudice determinations are made. If you are charged with a crime, it is important to understand what evidence the state may offer to attempt to prove your guilt, and you should consult a capable Michigan criminal defense lawyer to discuss your rights.

The Facts of the Case

It is reported that the defendant was convicted of second-degree murder and numerous other crimes following the shooting death of his wife. During the trial, the state introduced evidence of the defendant’s past infidelity, among other things. Following his conviction, the defendant filed an appeal, arguing in part that the trial court improperly permitted evidence of his infidelity. The appellate court disagreed and affirmed his conviction.

Evaluating Whether Evidence is Relevant or Prejudicial

The appellate court noted that the parties did not dispute that the defendant shot his wife; rather, the issue was whether the shooting constituted murder or voluntary manslaughter. To demonstrate guilt for voluntary manslaughter, the state needs to show that a person killed someone in the heat of passion that was brought about by sufficient provocation. The state must also show that there was not a lapse of time between the provocation and the event during which a rational person could gain control of their emotions.

At trial, the defendant argued that after finding out his wife was unfaithful, he was so overwhelmed with passion he could not control himself. The state introduced evidence of his infidelity to refute this assertion, which it argued made it relevant. The appellate court explained that evidence will be deemed relevant if it has a tendency to make a fact that is of consequence less or more probable. Thus, it has two elements: materiality and probative value. The appellate court found that both elements were met in the subject case in that it went to the core issue of whether the defendant was adequately provoked.

Turning to the issue of whether the evidence was unduly prejudicial, the appellate court explained that evidence will only be deemed unfairly prejudicial if it is marginally probative but would be given preemptive weight. As the appellate court found that the risk of prejudice created by the evidence was minimal, the defendant did not meet this burden.

Confer with an Experienced Michigan Criminal Defense Attorney

Criminal defendants are protected from unjust tactics during their trials, including the introduction of improper evidence. If you are accused of committing a crime, it is crucial to mount a compelling defense, and you should confer with an attorney as soon as possible. Sam Bernstein of ArborYpsi Law is an experienced Michigan criminal defense lawyer who is proficient at helping people fight criminal charges, and if you hire him, he will work tirelessly on your behalf. You can reach Mr. Bernstein through the form online or by calling (734) 883-9584 to set up a conference.