People v. Cameron
291 Mich. App. 599
| Mich. Ct. App. | 2011Background
- Cameron was convicted of domestic violence (third offense) and sentenced as a second-offense habitual offender to six months to three years in prison, affirmed on appeal.
- The offense occurred Sept. 19, 2008, involving Cameron's assault of his ex-girlfriend Kristie Yacheson in her Royal Oak apartment; a no-contact order prohibited Cameron’s presence.
- Yacheson invited friends over; Cameron visited despite the order, brought food and beer, and drank with others present.
- During the visit, Cameron allegedly pushed Yacheson twice, then against a refrigerator and stove, with further alleged punching or jabbing; police arrived as Cameron left, and he was arrested after a chase and struggle.
- Yacheson gave police a statement; officers observed her distressed state but no visible injuries at the scene; the no-contact order was verified.
- Before trial, the prosecutor sought and the court admitted evidence of Cameron’s prior domestic-violence acts against Yacheson and Pamela Ponder under MCL 768.27b to show propensity and credibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior-bad-acts evidence | Cameron argues MCL 768.27b should exclude due to unfair prejudice. | Cameron contends the acts are probative and admissible under 403 balancing to show history and credibility. | Admissible under MCL 768.27b; probative value not substantially outweighed by prejudice. |
| Sufficiency of the evidence for domestic violence | State's evidence supports each element beyond a reasonable doubt. | Cameron argues insufficiently proven assault/assault and battery. | Evidence supported intent and the charged elements; rational jurors could convict. |
| Great weight of the evidence | Great-weight challenge should reverse; evidence overwhelmingly supported verdict. | Verdict contrary to weight of evidence; new trial warranted. | No plain error; verdict not against the great weight of the evidence. |
Key Cases Cited
- People v Hine, 467 Mich 242 (Mich 2002) (standard for admissibility of prior acts in domestic-violence cases)
- People v Nowack, 462 Mich 392 (Mich 2000) (preserves balancing of probative value vs prejudice; domestic-violence context)
- People v Pattison, 276 Mich App 613 (Mich App 2007) (analysis of 768.27a in minor-offense context; relevance to DV acts)
- People v Schultz, 278 Mich App 776 (Mich App 2008) (MCL 768.27b admissibility framework for domestic-violence acts)
- People v Fisher, 449 Mich 441 (Mich 1995) (recognized evidentiary standards in domestic-violence prosecutions)
- People v Stanaway, 446 Mich 643 (Mich 1994) (general evidentiary standards and acknowledgment of credibility determinations)