People v. Wood, 862 N.W.2d 7

Wood was convicted of first-degree premeditated murder and first-degree felony murder, larceny in a building, and two financial transaction device offenses; sentenced as a fourth habitual offender to life without parole for murder and concurrent terms for other offenses; conviction affirmed on appeal.
Co-defendant Watson pleaded guilty to lesser offenses and testified against Wood at trial.
Dailey, an 80-year-old woman, was killed on November 20, 2011; extensive blunt and sharp-force injuries and ligature marks were found; Dailey’s valuable items, including credit cards, were stolen.
Evidentiary decisions included admission of other acts evidence (three prior thefts) under MRE 404(b) to show intent, scheme, and common plan, and the State sought to prove Wood’s motive and premeditation.
The defense challenged prosecutorial misconduct, DNA evidence (Y-STR testing) admissibility, confrontation rights regarding preliminary exam testimony, and jury instructions; the court rejected these challenges and upheld the convictions.
Key DNA testimony established Y-STR haplotype matches linking Wood to major male donors in scarf and fingernails; the court found the Y-STR analysis admissible under MRE 702 with Daubert-based reliability considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of other acts evidence under MRE 404(b)	Wood argues 404(b) admission was improper	Ackerman-esque claim of unfair prejudice and lack of probative value	Admissible for multiple proper purposes; probative value not substantially outweighed by prejudice
Prosecutorial misconduct in opening statement	State improperly vouched for Watson’s credibility	Prejudicial error requiring mistrial	Not reversible; curative jury instructions cured potential prejudice
Admissibility of Y-STR DNA testing under MRE 702/403	Y-STR testing provides probative, reliable male DNA evidence	Testosterone/limitations of Y-STR as non-unique; possible prejudice	Admissible; testing properly grounded in reliability and standards; probative value not substantially outweighed by prejudice
Confrontation clause and admissibility of Altesleben’s preliminary examination testimony	Reading of unavailable witness’ prior testimony violated confrontation	No actionable error; ineffective assistance not established	No confrontation error; unpreserved issue reviewed for plain error; proper use of MRE 804(b)(1)
Accomplice jury instruction regarding Watson	Instruction bolstered accomplice credibility	Instruction improper or incomplete	Waived by defense approval; instruction modeled on standard guidance; no reversible error

People v Sabin (After Remand), 463 Mich 43 (2000) (admissibility of 404(b) evidence for proper purposes)
People v Jambor (On Remand), 273 Mich App 477 (2007) (de novo review of admissibility; abuse of discretion standard)
People v Starr, 457 Mich 490 (1998) (probative value vs prejudice under 403 for prior acts)
People v Ackerman, 257 Mich App 434 (2003) (limiting instructions and admissibility considerations)
People v Comella, 296 Mich App 643 (2012) (premeditation and deliberation linked to other acts evidence)
People v Kowalski, 492 Mich 106 (2012) (Daubert reliability factors for DNA testing)
Gilbert v. DaimlerChrysler Corp., 470 Mich 749 (2004) (Daubert standard for expert testimony reliability)
Unger v. Michigan, 278 Mich App 210 (2008) (Daubert-type reliability; standard for expert testimony)
People v Hall, 433 Mich 573 (1989) (evidence explaining circumstances of crime; non-404(b) admissibility)
People v Meredith, 459 Mich 62 (1998) (Confrontation/804(b)(1) cross-examination foundations)
People v Jensen, 162 Mich App 171 (1987) (accomplice testimony and jury instruction adequacy)
People v Morris, 139 Mich App 550 (1984) (804(b)(1) prior testimony admissibility)
Garland v. People, 286 Mich App 1 (2009) (availability and admissibility of former testimony; confrontation)