People of Michigan v. Ryan Patrick Smith

Michigan Court of Appeals·Decided July 16, 2026·No. 372353·Unpublished

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED July 16, 2026 Plaintiff-Appellee, 12:30 PM

v No. 372353 Allegan Circuit Court RYAN PATRICK SMITH, LC No. 2022-025164-FH

Defendant-Appellant.

Before: ACKERMAN, P.J., and REDFORD and FEENEY, JJ.

PER CURIAM.

Defendant appeals as of right his jury trial convictions of two counts of second-degree criminal sexual conduct (CSC-II), MCL 750.520c(1)(b) (sexual contact with a household member between the ages of 13 and 16), and two counts of domestic violence, MCL 750.81(2). Defendant was sentenced to 4 to 15 years’ imprisonment for the CSC-II convictions and 4 days in jail for the domestic violence convictions. We affirm.

I. FACTUAL BACKGROUND

This case arises from defendant engaging in sexual contact with his stepdaughters, AS and KP. On numerous occasions, defendant touched AS and KP on their upper inner thighs, near the pubic bone, when they rode in his vehicle. Defendant did not touch his sons in this manner. Moreover, in 2021, defendant entered AS’s bedroom, walked over to her, and pulled up her shirt before asking her why she was wearing a sports bra. That same morning, defendant entered KP’s bedroom, picked up and threw KP over his shoulder, and started hitting KP’s butt approximately five to six times while saying, “Charlie Horse.” KP also accused defendant of touching her vagina area with his foot. Defendant was later arrested and charged with three counts of CSC-II and two counts of domestic violence.

Before trial, the prosecution provided defendant with a notice of intent to admit evidence under MCL 768.27a(1). At trial, AS’s close friend, CT, who frequently visited AS, accused defendant of engaging in inappropriate conduct, which will be discussed further below. Defendant was found guilty of two counts of CSC-II and two counts of domestic violence.

-1- II. DISCUSSION

A. STANDARD OF REVIEW

Defendant argues that testimony was improperly admitted under MCL 768.27a(1) because it did not involve defendant engaging in a listed offense against a minor. Generally, “[a] trial court’s decision to admit evidence will not be disturbed absent an abuse of discretion.” People v Propp, 508 Mich 374, 383; 976 NW2d 1 (2021). “An abuse of discretion occurs when a decision falls outside the range of reasonable and principled outcomes, and a trial court necessarily abuses its discretion when it makes an error of law.” People v Crumbley, 346 Mich App 144, 167; 11 NW3d 576 (2023) (quotation marks and citation omitted). “However, whether a rule or statute precludes admission of evidence is a preliminary question of law that this Court reviews de novo.” Propp, 508 Mich at 383.

B. MCL 768.27a(1)

Defendant argues that he is entitled to a new trial because the trial court improperly admitted evidence under MCL 768.27a(1). We disagree.

MRE 402 states the general rule that all “[r]elevant evidence is admissible unless” excluded, in part, by another rule of evidence.

Evidence is relevant if:

(a) it has any tendency to make a fact more or less probable than it would be without the evidence; and

(b) the fact is of consequence in determining the action. [MRE 401.]

Generally, character evidence is inadmissible when offered to establish a defendant’s propensity to commit the charged offense under MRE 404(a)(1). People v Watkins, 491 Mich 450, 468; 818 NW2d 296 (2012). This Court has long recognized that character evidence is relevant in determining a defendant’s guilt or innocence, as “an individual with a substantial criminal history is more likely to have committed a crime than is an individual free of past criminal activity.” Id. at 470 (quotation marks and citation omitted). Thus, character evidence is not generally precluded at trial based on its relevance, but rather to protect a defendant against a jury convicting a defendant based on character rather than the evidence before the court in the current case. Id. at 468. Also, “propensity evidence might weigh too much with the jury and . . . so overpersuade them as to prejudge one with a bad general record and deny him a fair opportunity to defend against a particular charge.” Id. at 468-469 (quotation marks and citation omitted).

Although character evidence is generally inadmissible in criminal cases when offered to establish a defendant’s propensity to commit the charged offense, MCL 768.27a(1) allows the prosecution to offer character evidence against a defendant charged with certain listed offenses against a minor. MCL 768.27a(1) and (2) provide that,

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

-2- against a minor is admissible and may be considered for its bearing on any matter to which it is relevant. If the prosecuting attorney intends to offer evidence under this section, the prosecuting attorney shall disclose the evidence to the defendant at least 15 days before the scheduled date of trial or at a later time as allowed by the court for good cause shown, including the statements of witnesses or a summary of the substance of any testimony that is expected to be offered.

(2) As used in this section:

(a) “Listed offense” means that term as defined in section 2 of the sex offenders registration act, 1994 PA 295, MCL 28.722.

Because MCL 768.27a(1) allows for other bad acts evidence to “be considered for its bearing on any matter to which it is relevant,” including to establish a defendant’s propensity to commit the charged offense, “MCL 768.27a permits the admission of evidence that MRE 404(b) precludes.” Watkins, 491 Mich at 470. “Thus, the statute establishes an exception to MRE 404(b) in cases involving a charge of sexual misconduct against a minor.” Id. at 471.

Where listed offenses are at issue, the analysis begins and ends with MCL 768.27a. If listed offenses are not at issue, even where an uncharged offense may genuinely constitute an offense committed against a minor that was sexual in nature, MCL 768.27a is not implicated, but this is not to say that evidence of the offense is inadmissible. We do not construe MCL 768.27a as suggesting that evidence of an uncharged sexual offense committed against a minor is inadmissible if the offense does not constitute a listed offense. Rather, the analysis simply turns to MRE 404(b) to decipher admissibility. Only where the evidence does not fall under the umbrella of MCL 768.27a, nor is otherwise admissible under MRE 404(b), should the court exclude the evidence. [People v Smith, 282 Mich App 191, 205-206; 772 NW2d 428 (2009).]

Defendant argues that the trial court improperly admitted a plethora of inadmissible testimony at trial over his standing objection to preclude testimony about defendant engaging in other nonsexual conduct with other minors, by arguing that such conduct was not a listed offense under MCL 768.27a(1). Specifically, defendant argues that the following list of testimony was inadmissible:

A. Defendant would tickle the children;

B. An incident where the defendant lifted up the crop top being worn by [AS] and commented about the impropriety of the sports bra she was wearing;

C. Defendant’s habit of barging into the girls’ bedroom without announcing himself;

D. A one-time incident where the defendant put donuts into two girls’ mouths;

-3- E. A one-time incident where the defendant brushed sand from one of the girls[;]

F.

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