People v. Jackson
498 Mich. 246
Mich.2015Background
- Defendant Timothy W. Jackson, a church pastor, was convicted by a jury of six counts of first‑degree criminal sexual conduct for repeatedly sexually abusing a 12–13‑year‑old parishioner who served as a "youth nurse."
- The complainant disclosed the abuse to her aunt, Jacklyn Price, who testified that she approached the complainant after discussions with a former parishioner (Latoya Newsome) and because of Price’s own prior sexual history with the defendant. Price’s testimony suggested prior sexual relationships between defendant and Price/Newsome.
- Defense objected at trial under MRE 404(b) (other‑acts rule) and moved for a mistrial; the trial court ruled the testimony was not other‑acts evidence and allowed it without 404(b) pretrial notice.
- The Court of Appeals agreed the testimony was other‑acts evidence but held it was admissible under a “res gestae exception” to MRE 404(b); a concurrence disagreed with the exception but found the error harmless.
- The Michigan Supreme Court reviewed whether Price’s testimony was governed by MRE 404(b), whether a res gestae exception exists, and whether any notice failure was prejudicial; it held: (1) the testimony was other‑acts evidence governed by MRE 404(b); (2) there is no res gestae exception to MRE 404(b); but (3) the admission error was harmless and convictions were affirmed.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Jackson) | Held |
|---|---|---|---|
| Whether Price's testimony constituted "other acts" under MRE 404(b) | Testimony explained why Price questioned the victim and was not evidence of prior bad acts for propensity | Testimony indicated prior sexual relationships and thus was impermissible other‑acts evidence used for propensity inference | Yes. Court: testimony was other‑acts evidence governed by MRE 404(b) |
| Whether a "res gestae" exception lets such evidence bypass MRE 404(b) | N/A (People relied on admissibility for proper purpose) | Trial court and Court of Appeals majority argued "res gestae"/"complete the story" allowed admission without 404(b) analysis | No. Court: no res gestae exception to MRE 404(b); Delgado and Sholl do not exempt such evidence from 404(b) scrutiny |
| Whether the prosecutor’s failure to provide MRE 404(b)(2) notice required reversal | Evidence was admitted for a proper, non‑propensity purpose and notice failure caused no outcome‑determinative prejudice | Lack of reasonable pretrial notice was prejudicial and warranted relief | No reversal. Court: notice requirement was violated but error was harmless; defendant showed no outcome‑determinative prejudice |
| Whether admission of Price’s testimony undermined verdict (harmlessness) | Testimony was relevant to motive for disclosure and tailored; other corroborating physical and testimonial evidence was overwhelming | Admission invited improper character inference and prejudiced jury | Harmless error. Substantively admissible under 404(b); other evidence strongly corroborated guilt |
Key Cases Cited
- People v Delgado, 404 Mich 76 (1978) (discusses evidence "inextricably related" and "complete story" concept)
- People v Sholl, 453 Mich 730 (1996) (applies Delgado "res gestae" concept to context and full transaction rationale)
- People v VanderVliet, 444 Mich 52 (1992) (framework for admissibility of other‑acts evidence; pretrial notice requirement)
- People v Mardlin, 487 Mich 609 (2010) (MRE 404(b) as inclusionary rule and burden to show non‑propensity purpose)
- People v Starr, 457 Mich 490 (1998) (other‑acts evidence admissible to rebut fabrication theory; necessity to "complete the story")
- People v Douglas, 496 Mich 557 (2014) (harmless‑error standard for preserved nonconstitutional evidentiary error)