People of Michigan v. Frederick James Mardlin

Summary

The court held that evidence of four prior fires involving property owned or controlled by defendant was admissible to rebut his claim that the charged fire was accidental. The evidence was relevant under the doctrine of chances because the unusual frequency of fires objectively suggested that at least one resulted from human design, and it was not offered solely to prove defendant's character or propensity. The trial court also did not abuse its discretion under MRE 403 because the evidence was highly probative and any unfair prejudice was limited. Chief Justice Kelly, dissenting, would have found the evidence insufficiently similar, unfairly prejudicial, and outcome-determinative error requiring a new trial.