People of Michigan v. Fred Huston-Darnell Chandler
People of Michigan v. Fred Huston-Darnell Chandler
Opinion
I concur in the Court's order denying leave to appeal because I agree with the Court of Appeals that any error in the trial court's decision to admit other-acts evidence under MRE 404(b) was harmless. I write separately, however, because I disagree with the Court of Appeals' 404(b) analysis. I believe that the trial court abused its discretion by admitting the other-acts evidence.
Although the Court of Appeals correctly recited the relevant standard from
People v. Golochowicz
,
But more-alike-than-different is not the standard, as the panel recognized. Rather, the crime must be " 'so unusual and distinctive as to be like a signature,' "
Golochowicz
,
The "peculiarities" identified here were (1) robbing "a small, local business," (2) giving an excuse when confronted about the shoplifting, and (3) fleeing the scene at high speed on residential streets. Chandler (On Remand) , unpub. op. at 5. The panel did not describe the characteristics of "the general class of offenses" against which the defendant's crimes stood out as atypical. Id . Nor do these "peculiarities" seem peculiar enough to be like a signature.
Thus, in my view, the evidence did not satisfy Golochowicz and admitting it was error. But I agree with the Court of Appeals' alternative holding that any error was harmless in light of the "abundant other evidence" from which the jury could infer identity. Id . at 6.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.