Michigan v. Jackson (Opinion on Application)
Annotate this CaseDefendant Timothy Jackson was convicted by a jury on six counts of first-degree criminal sexual conduct for sexually abusing a young member of the church where he served as pastor. At trial, the complainant’s aunt testified that she had approached the complainant to discuss the possible abuse in light of her own experiences and after talking with another woman who had also worked with defendant and had subsequently left the church. Defense counsel objected and moved for a mistrial, arguing that this testimony indicated that defendant had engaged in sexual relationships with the complainant’s aunt and her acquaintance, and was inadmissible evidence of other acts under MRE 404(b). The trial court overruled the objection and denied the motion, ruling that admissibility of the testimony was not governed by MRE 404(b) because the testimony was not evidence that defendant had engaged in prior sexual conduct with underage parishioners. The Court of Appeals affirmed, holding that although the testimony was evidence of other acts under MRE 404(b), it fell within an exception to that rule for res gestae evidence and thus could be admitted without reference to or compliance with the rule. Upon review, the Michigan Supreme Court agreed with the Court of Appeals that the testimony was other-acts evidence as contemplated by MRE 404(b), and that the trial court erred in concluding otherwise. However, the Court disagreed with the Court of Appeals majority that the trial court’s failure to subject the testimony to scrutiny under MRE 404(b) was nonetheless correct because the testimony fell within a "res gestae exception" to that rule. Because the testimony at issue constituted evidence of "other acts" as contemplated by MRE 404(b), its admission was governed by that rule and its procedural requirements. The Supreme Court agreed with the Court of Appeals’ determination that the defendant’s convictions should be affirmed, as defendant has failed to show entitlement to relief on the basis of this error. The Court therefore affirmed defendant’s convictions, but vacated that portion of the opinion of the Court of Appeals majority reasoning that the testimony at issue could be admitted without reference to or compliance with MRE 404(b) by virtue of a res gestae exception" to that rule.
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