Severance & joinder; MCR 6.120(B) & (C); People v. Williams; Carrying a concealed weapon (CCW)

The court held that the trial court did not err by denying the defendant’s motions to reconsider its order consolidating two criminal cases against him, or in the alternative to sever the charges for separate trials. He was charged with arson and CCW in separate cases. The trial court granted the prosecution’s motion to consolidate the cases, over defendant’s objection. On appeal, the court rejected his argument that the charged arson and CCW offenses were not “related” under MCR 6.120(B)(1), noting that the two charges “shared some of the same facts and circumstances and, according to the prosecution’s representations, contained areas of overlapping proof.” Thus, the trial court’s decision to consolidate the cases was not outside the range of principled outcomes. Although defendant took issue with the prosecution’s failure to identify what evidence from his arrest "would be introduced at trial, we do not find that the prosecution’s lack of specificity renders the trial court’s decision an abuse of discretion.” Affirmed.