People of Michigan v. Douglas Henry Thoms

CourtMichigan Court of Appeals
DecidedDecember 22, 2025
Docket373296
StatusUnpublished

This text of People of Michigan v. Douglas Henry Thoms (People of Michigan v. Douglas Henry Thoms) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. Douglas Henry Thoms, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED December 22, 2025 Plaintiff-Appellee, 9:44 AM

v No. 373296 Lenawee Circuit Court DOUGLAS HENRY THOMS, LC No. 2023-021221-FC

Defendant-Appellant.

Before: GADOLA, C.J., and CAMERON and RICK, JJ.

PER CURIAM.

Defendant appeals as of right his jury-trial convictions of first-degree criminal sexual conduct (CSC-I), MCL 750.520b(1)(a) (victim under 13 years of age), second-degree child abuse, MCL 750.136b(3), and two counts of second-degree criminal sexual conduct (CSC-II), MCL 750.520c(1)(a) (victim under 13 years of age).1 Defendant was sentenced to 25 to 50 years’ imprisonment for the CSC-I conviction, 71 to 180 months’ imprisonment for each CSC-II conviction, and 71 to 120 months’ imprisonment for the second-degree child abuse conviction. We affirm.

I. FACTUAL BACKGROUND

This case arises from defendant’s convictions of alleged sexual and physical abuse against his stepdaughter, GT, who was born in March 2001. She lived with defendant and her mother in Adrian, Michigan, starting when she was three or four years old. According to GT, defendant punished her by making her “hold boots out to either side of [her] body for an extended period of time.” She also claimed defendant grabbed her hair and shook her until her nose bled. GT alleged the first sexual assault in this matter occurred when she was five years old.

When GT was 9 or 10 years old, the family moved to a new house, which was infested with fleas and bed bugs. Defendant performed “flea checks[]” by telling GT to take off her clothes.

1 Defendant was acquitted of indecent exposure, MCL 750.335a(2)(a).

-1- She stated defendant “would look at my body and he would run his fingers along my body, like on my breast area, on my thighs, and my butt.” She approximated that these flea checks happened about 50 times over several years. Two years later, when GT was 12 years old, she alleged that defendant exposed his penis to her and assaulted her with a vibrator. GT also stated that defendant and GT’s mother hosted religious “rituals[]” involving the Wicca religion. According to GT, defendant had a machete on an “altar[]” in the living room, and he “would be possessed and take the machete, walk around with it.” At one of defendant’s gatherings, which also occurred when GT was 12 years old, he grabbed her shirt and held the machete up to her neck.

Defendant was charged with CSC-I, CSC-II, second-degree child abuse, and indecent exposure, under MCL 750.335a(2)(a). The district court added a second count of CSC-II at the preliminary examination, based on GT’s testimony about the flea checks. The jury convicted defendant of CSC-I, both counts of CSC-II, and second-degree child abuse. It acquitted him of indecent exposure. The trial court sentenced defendant as earlier described. This appeal followed.

II. ANALYSIS

A. OTHER ACTS EVIDENCE

Defendant argues he was denied a fair trial when the trial court admitted unfairly prejudicial other acts evidence about the flea checks. We disagree.

Generally, this Court reviews a trial court’s decision to admit evidence for an abuse of discretion. People v Bass, 317 Mich App 241, 255; 893 NW2d 140 (2016) (quotation marks and citation omitted). “An abuse of discretion occurs when the [trial] court chooses an outcome that falls outside the range of reasonable and principled outcomes.” Id. at 256 (quotation marks and citation omitted). Further, this Court reviews “any preliminary legal questions regarding admissibility” de novo. Id. at 255 (citation omitted). A trial court’s error in admitting evidence is not a ground for reversal “unless, after an examination of the entire cause, it affirmatively appears that it is more probable than not that the error was outcome determinative.” People v Solloway, 316 Mich App 174, 192; 891 NW2d 255 (2016) (quotation marks and citation omitted).

Defendant contends that evidence of the flea checks was inadmissible because it was offered only to show his bad character and propensity to commit sexual assault. The prosecution introduced the flea check evidence under MCL 768.27a.2 Under the statute, “in a criminal case in which the defendant is accused of committing a listed offense against a minor, evidence that the defendant committed another listed offense against a minor is admissible and may be considered for its bearing on any matter to which it is relevant.” MCL 768.27a(1). Such evidence may be considered for its relevance to any matter, including the defendant’s character or propensity to commit the charged offense. People v Hoskins, 342 Mich App 194, 201-202; 993 NW2d 48 (2022). The flea check evidence was offered as evidence of other acts of CSC-II against GT, which is a listed offense under MCL 768.27a. See MCL 768.27a(2)(a). Thus, the evidence was

2 Given that the prosecution only sought to admit the evidence under MRE 768.27a, we decline to address the portion of defendant’s argument that makes reference to MRE 404(b).

-2- admissible under MCL 768.27a to show defendant’s character or propensity to commit the charged crimes.

Even so, defendant asserts that the evidence should have been excluded under MRE 403. See People v Beck, 510 Mich 1, 20; 987 NW2d 1 (2022) (“[E]ven if the evidence is admissible under MCL 768.27a, it must still comply with MRE 403.”). Under MRE 403, relevant evidence may nevertheless “be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” “Unfair prejudice occurs when there exists a danger that marginally probative evidence will be given undue or preemptive weight.” Beck, 510 Mich at 20 (quotation marks and citations omitted). Our Supreme Court has identified a nonexhaustive list of factors that courts must consider when determining whether to exclude other-acts evidence as unfairly prejudicial, including:

(1) [T]he dissimilarity between the other acts and the charged crime, (2) the temporal proximity of the other acts to the charged crime, (3) the infrequency of the other acts, (4) the presence of intervening acts, (5) the lack of reliability of the evidence supporting the occurrence of the other acts, and (6) the lack of need for evidence beyond the complainant's and the defendant’s testimony. [People v Watkins, 491 Mich 450, 487-488; 818 NW2d 296 (2012) (footnote omitted).]

“[C]ourts must weigh the propensity inference in favor of the evidence’s probative value rather than its prejudicial effect.” Id. at 487.

Defendant has not identified any considerations that would warrant excluding the flea check evidence as unfairly prejudicial. He asserts that the number of alleged flea checks, exceeding 50 over several years, prejudiced him and confused the issues in this matter. Defendant makes no effort to substantiate his argument that the evidence confused the issues, other than to state that the evidence was distracting to the jury. However, defendant proffers no evidence that the jury was unduly preoccupied with or distracted by the other-acts evidence. Regarding unfair prejudice, defendant simply contends that the sheer frequency of the alleged incidents should weigh against their admission, in an apparent inversion of the Watkins factor pertaining to the frequency of other acts. Critically, courts take into consideration “the infrequency of the other acts,” not their frequency, when deciding whether to exclude other-acts evidence as unfairly prejudicial. Id.

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People v. Trakhtenberg
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People v. Watkins; People v. Pullen
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People v. Kowalski
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People v. Sabin
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People v. Carter
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People v. Hoag
594 N.W.2d 57 (Michigan Supreme Court, 1999)
People v. Ginther
212 N.W.2d 922 (Michigan Supreme Court, 1973)
People v. Solloway
891 N.W.2d 255 (Michigan Court of Appeals, 2016)
People v. Bass
893 N.W.2d 140 (Michigan Court of Appeals, 2016)
People v. Ericksen
793 N.W.2d 120 (Michigan Court of Appeals, 2010)
People v. Eisen
820 N.W.2d 229 (Michigan Court of Appeals, 2012)

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Bluebook (online)
People of Michigan v. Douglas Henry Thoms, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-douglas-henry-thoms-michctapp-2025.