Evidence Sufficiency In An Arson Case
In People v. Wolford, 189 Mich App 478; 473 NW2d 767 (1991), the defendant challenged the sufficiency of the evidence in an arson case.
Specifically, the defendant argued that the prosecution failed to negate the possibility that the fire was caused by an accident and failed to prove that the defendant was responsible for the fire. Id. at 479.
The Court stated that the prosecution is not required to introduce direct evidence linking a defendant to a crime, rather, circumstantial evidence and reasonable inferences arising from it may constitute satisfactory proof of arson. Id.
In affirming the jury's verdict of conviction, this Court referenced circumstantial evidence including, in part, testimony that the defendant was seen outside the trailer he was accused of burning about ten minutes before flames were seen coming from the trailer. Id. at 481.
Additionally, in People v. Simon, 174 Mich App 649, 654; 436 NW2d 695 (1989), the Court declined to hold that where no residue of an accelerant was found, the proof of arson was insufficient as a matter of law.
The Court reasoned that to do so would allow arsonists to escape punishment where the fire successfully destroys detectable amounts of residue. Id.
Fire investigators should not be responsible to investigate all remotely possible causes of a fire for which no evidence exists. Id.