Other acts evidence; MCL 768.27b; People v Watkins; Unfair prejudice; MRE 403; People v Cameron; Sufficiency of the evidence; People v Harris; CSC I elements; MCL 750.520b(1)(b); People v Phillips; Third-degree child abuse elements; MCL 750.136b(5); People v Jarrell; Domestic violence elements; MCL 750.81(2); People v Cameron

The court held that the trial court did not abuse its discretion by admitting domestic-violence other acts evidence under MCL 768.27b and that sufficient evidence supported defendant’s CSC I, third-degree child abuse, and domestic violence convictions. Defendant’s CSC and child abuse convictions involved his 15-year-old stepson, and his domestic violence conviction involved his wife. There was evidence that he beat the stepson with a shoehorn and “jabbed” it into the anal area through clothing and later assaulted his spouse by grabbing her neck and punching her face. On appeal, the court held MCL 768.27b permits “evidence of the defendant’s commission of other acts of domestic violence” for any relevant purpose subject to MRE 403, and it concluded the prior acts were probative of propensity, provided context for the relationships, and helped explain delayed disclosure. Applying the Watkins factors, it found similarity and temporal proximity supported admission and the evidence’s probative value was not substantially outweighed by unfair prejudice, particularly where courts should weigh the propensity inference in favor of probative value in this setting. The court also held the evidence was sufficient for CSC I because the object entered between the victim’s “butt cheeks,” and “entry into the anal canal is not required,” the victim was 15, and defendant was a household member. It affirmed the child abuse conviction based on testimony that defendant knowingly caused physical harm to a child under his authority by repeatedly striking him with the shoehorn. It affirmed the domestic violence conviction based on testimony and officer-observed marks corroborating that defendant assaulted and battered his spouse. Affirmed.