People of Michigan v. Aaron Matthews
330933
| Mich. Ct. App. | May 11, 2017Background
- In early March 2015 at a Detroit community-center event, defendant Aaron Matthews shot and killed Edward Childress III, fired on others, and later attempted/committed related robberies and carjacking; multiple victims were shot and one later died.
- Police charged Matthews with second-degree murder, carjacking, assault with intent to commit murder (AWIM), felon-in-possession, felony-firearm, and related counts; he was convicted by a jury and received lengthy prison terms.
- Before trial the prosecutor sought to admit MRE 404(b) other-acts evidence of (1) an armed robbery on Grayton Street (Feb 28, 2015) and (2) a homicide on Maiden Street (Mar 1, 2015), arguing relevance to identity and common scheme or plan.
- Defense contested admissibility, arguing dissimilarity and that probative value was substantially outweighed by unfair prejudice under MRE 403.
- The trial court admitted the other-acts testimony (witnesses Baker and Tekiyus Williams) with a limiting instruction restricting juror use to identity/common scheme; the jury convicted Matthews and acquitted on some related counts, suggesting jurors followed instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court properly admitted other-acts evidence under MRE 404(b) | Other-acts evidence is admissible to prove identity and common scheme or plan; probative value outweighs prejudice | Evidence was too dissimilar and unfairly prejudicial under MRE 403 | Admissible: court found a non-propensity purpose (identity/common scheme), relevance, and no undue prejudice |
| Whether the probative value was substantially outweighed by unfair prejudice (MRE 403) | Evidence was highly probative (similar language, weapon use, modus operandi) and limiting instruction mitigated prejudice | Other-acts evidence would inject bias, sympathy, or anger, and risked undue weight | Probative value not substantially outweighed; limiting instruction and jury’s verdicts support no unfair prejudice |
| Whether limiting instruction cured any potential prejudice | Limiting instruction restricted jury to consider evidence only for identity/scheme, not propensity | Instruction insufficient to eliminate risk of undue prejudice | Instruction was adequate; jurors presumed to follow instructions; verdicts indicate compliance |
| Standard of review for evidentiary ruling | N/A (prosecution defending trial court) | Abuse-of-discretion review: trial court must not err in law | No abuse of discretion: evidentiary rulings compatible with MRE 401, 402, 403 and 404(b) principles |
Key Cases Cited
- People v. Bynum, 496 Mich. 610; 852 N.W.2d 570 (discussing abuse-of-discretion review of evidentiary rulings)
- People v. Duncan, 494 Mich. 713; 835 N.W.2d 399 (trial court abuses discretion when decision falls outside reasonable range)
- People v. Mardlin, 487 Mich. 609; 790 N.W.2d 607 (other-acts admissibility and MRE 403 analysis)
- People v. Knox, 469 Mich. 502; 674 N.W.2d 366 (permissible purposes for MRE 404(b) evidence)
- People v. Cameron, 291 Mich. App. 599; 806 N.W.2d 371 (definition of unfair prejudice under MRE 403)
- People v. Roscoe, 303 Mich. App. 633; 846 N.W.2d 402 (limiting instructions can cure potential prejudice; jurors presumed to follow instructions)
- People v. McMillian, 213 Mich. App. 134; 539 N.W.2d 553 (other-acts admissibility principles)