People v. Uribe, 499 Mich. 921

Defendant Ernesto Evaristo Uribe was convicted in Eaton County; the trial court excluded proposed MCL 768.27a "other-acts" testimony under MRE 403.
The trial court relied on Watkins-era illustrative considerations (witness statement inconsistencies and dissimilarities between acts) to justify exclusion.
The Michigan Court of Appeals affirmed the exclusion; the State sought review by the Michigan Supreme Court.
The Supreme Court granted plenary consideration and, citing People v Watkins, analyzed whether the exclusion was an abuse of discretion.
The Supreme Court concluded the trial court misapplied Watkins: it failed to explain how the cited concerns made the evidence’s probative value substantially outweighed by unfair prejudice, and thus abused its discretion.
The Supreme Court vacated the Court of Appeals judgment, reversed the trial court’s exclusion, and remanded to the Eaton Circuit Court for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of proposed MCL 768.27a evidence	The other-acts testimony falls within MCL 768.27a and should be admitted; statute supersedes MRE 404(b) for such evidence	The evidence should be excluded under MRE 403 due to inconsistencies and dissimilarities making it unfairly prejudicial or misleading	The evidence is within MCL 768.27a; exclusion under MRE 403 was an abuse of discretion because the trial court failed to explain how prejudice substantially outweighed probative value
Standard of review for evidentiary ruling	Trial court decisions reviewed for abuse of discretion; appellate courts must apply Watkins guidance	Same	Court reaffirmed abuse-of-discretion standard and that Watkins governs analysis
Interaction of MCL 768.27a with MRE 404(b) and other rules	MCL 768.27a prevails over MRE 404(b) for in-scope evidence, but not automatically admitted—other evidence rules apply	Trial court may exclude under MRE 403 when appropriate	Court held statute does not mandate admission; courts must apply ordinary rules (MRE 403, hearsay, privilege) guided by Watkins
Proper application of Watkins considerations	Watkins provides illustrative considerations to guide, not replace, a concrete MRE 403 balancing	Trial court treated Watkins considerations as dispositive reasons to exclude	Court held trial court misused Watkins, failing to perform the required probative vs. prejudicial balancing and therefore reversed

People v. Watkins, 491 Mich. 450 (2012) (explains abuse-of-discretion review; MCL 768.27a supersedes MRE 404(b) for in-scope evidence but does not mandate admission; provides illustrative considerations for MRE 403 analysis)