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People v. Watkins, 491 Mich. 450, 818 N.W.2d 296

Facts

Defendants Lincoln Anderson Watkins and Richard Kenneth Pullen were convicted of multiple counts of criminal sexual conduct against minors. In Watkins's case, he was accused of molesting a 12-year-old girl, while Pullen faced allegations of sexual misconduct against his granddaughter. Both cases involved the prosecution's attempts to introduce evidence of prior sexual offenses against minors, leading to appeals regarding the admissibility of such evidence under Michigan law.

In Docket No. 142031, defendant, Lincoln Anderson Watkins, appeals by leave granted the judgment of the Court of Appeals affirming his convictions and sentences. Watkins was charged with five counts of first-degree criminal sexual conduct (CSC–I) and one count of second-degree criminal sexual conduct (CSC–II) for allegedly molesting a 12–year–old girl.

Issue

Whether MCL 768.27a conflicts with MRE 404(b) and whether the statute prevails over the court rule regarding the admissibility of evidence of prior acts of sexual misconduct against minors.

We granted leave, instructing the parties to address (1) whether MCL 768.27a conflicts with MRE 404(b) and, if it does, (2) whether the statute prevails over the court rule …

Rule

MCL 768.27a allows the admission of evidence of other acts of criminal sexual conduct against a child for its relevance, overriding MRE 404(b), which generally excludes such evidence if its only relevance is to show the defendant's character or propensity to commit the charged offense.

MCL 768.27a provides: (1) Notwithstanding [MCL 768.27], in a criminal case in which the defendant is accused of committing a listed offense against a minor, evidence that the defendant committed another listed offense against a minor is admissible and may be considered for its bearing on any matter to which it is relevant.

Analysis

The Court found that MCL 768.27a and MRE 404(b) irreconcilably conflict, as the former permits the admission of propensity evidence in cases involving sexual misconduct against minors, while the latter prohibits it. The Court emphasized that the statute does not infringe upon the Supreme Court's authority to regulate court procedures, as it serves a substantive purpose in addressing the serious nature of sexual offenses against minors.

Thus, the language in MCL 768.27a allowing admission of another listed offense 'for its bearing on any matter to which it is relevant' permits the use of evidence to show a defendant's character and propensity to commit the charged crime, precisely that which MRE 404(b) precludes.

Conclusion

The Michigan Supreme Court affirmed the Court of Appeals' judgment in part, vacated the lower courts' judgments in part, and remanded the cases for further proceedings consistent with its opinion, allowing the introduction of prior acts evidence under MCL 768.27a.

Accordingly, we affirm the judgment of the Court of Appeals in People v. Watkins, Docket No. 142031, vacate the judgments of the lower courts in People v. Pullen, Docket No. 142751, and remand the latter case to the trial court for further proceedings consistent with this opinion.

Who won?

The prevailing party was the prosecution, as the Court upheld the admissibility of prior acts evidence under MCL 768.27a, allowing the introduction of such evidence in the trials.

The Court of Appeals concluded that the testimony was relevant and not more prejudicial than probative and that any error by the trial court was harmless.

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