People v. Watkins

Lincoln Watkins (defendant) was convicted of sexually abusing his 12-year-old neighbor while she babysat Watkins’s youngest child. At trial, the prosecution introduced evidence from E.W., Watkins’s former babysitter, whom Watkins had abused when E.W. was 14 years old. E.W. never reported the sexual abuse, and Watkins was never charged. The jury convicted Watkins. Watkins appealed, arguing that E.W.’s testimony was improperly admitted because it was evidence of past acts submitted to prove Watkins’s propensity to sexually abuse minors. The appellate court affirmed, holding that E.W.’s testimony was admissible because it was a similar scenario and showed Watkins’s history of abusing a minor under similar circumstances. Watkins appealed. In a similar case, Richard Pullen (defendant) was convicted of indecent exposure for exposing himself to his 12-year-old granddaughter. At trial, the prosecution submitted a 1989 police report describing a pattern of sexual abuse and molestation committed by Pullen against his daughter, starting when she was five years old. No charges were ever filed in connection with the 1989 police report. After the state notified Pullen that it intended to introduce the 1989 police report, Pullen filed a motion to bar the admission, arguing that the report would be more prejudicial than probative both because the report was 20 years old, making it difficult for Pullen to defend himself against it, and because charges were never filed. The trial court granted Pullen’s motion, and the appellate court affirmed. The state appealed, and its appeal was consolidated with Watkins’s appeal before the Michigan Supreme Court.