Michigan Court Bars the Use of Other Acts Evidence in a Criminal Case

In attempting to establish a defendant’s guilt, the State will frequently try to introduce evidence of a scheme or motive. There are restrictions as to what is admissible, however. For example, in most instances, the State cannot introduce evidence of other crimes to show a defendant’s guilt. This was demonstrated in a recent Michigan case in which the court ruled that evidence of other crimes was inadmissible in a case in which the defendant is charged with first-degree murder. If you are charged with murder or any other violent crime, it is in your best interest to speak with an experienced Michigan criminal defense attorney about your rights.

The History of the Case

Reportedly, the defendant’s co-worker, who per eyewitness reports was last seen with the defendant, was missing. The police began investigating her disappearance and questioned the defendant. He advised them that he was working when she disappeared, even though he was not. Thus, the police became suspicious of the defendant and obtained a warrant to search his apartment. As part of the search, they performed a DNA analysis that indicated the presence of the skin cells on the defendant’s rug.

Allegedly, the State charged the defendant with the first-degree murder of the co-worker solely due to the DNA evidence. Before the trial, the prosecution filed a motion in limine asking the court to permit the introduction of evidence that the defendant had a prior conviction for strangling and attempting to rape another woman. The defense attorney argued such information was inadmissible other acts evidence, which would be used to unjustly indicate the defendant’s propensity to commit crimes. The trial court found in favor of the defendant, and the State appealed.

The Use of Other Acts Evidence in Criminal Cases

On appeal, the State argued the defendant’s previous offense was similar to his current charge, and as such, evidence of the prior crime should be admitted to show, among other things, the defendant’s intent, motive, and common plan, scheme, or system. The appellate court declined to adopt the State’s reasoning.

Under the Michigan Rules of Evidence, evidence of other crimes, wrongs, or acts cannot be used to show a propensity to commit such acts. It may be admitted into evidence, though, for other purposes, like showing intent, motive, opportunity, or a scheme or plan.

The courts will perform a three-part test to evaluate whether other acts evidence should be admitted. Specifically, they assess whether the evidence is being offered for a valid purpose, then they evaluate whether it is relevant. Last, they will weigh whether its probative outweighs the risk of prejudice. Here, the appellate court ultimately found that the State failed to prove the other acts evidence should be admitted for any reason. As such, it affirmed the trial court ruling.

Speak to Seasoned Michigan Criminal Defense Attorney

The prosecution cannot use unlawful evidence to prove a defendant’s guilt, and if it does, it may be grounds for a reversal of a conviction. If you are charged with a crime, it is smart to speak to an attorney as soon as possible. Sam Bernstein of ArborYpsi Law is a seasoned Michigan criminal defense attorney who will work hard to preclude any unjust evidence from being used against you at trial to provide you with a strong chance of a favorable outcome. You can reach Mr. Bernstein via the online form or by calling (734) 883-9584 to set up a meeting.