By Judy Reed

The Michigan Court of Appeals has upheld the first-degree murder conviction of Timothy Allen Dawson in the murder of his wife Julia, in December 2004.

Dawson had reported her missing from their Sparta home, on December 11, 2004. Her strangled and bludgeoned body was found three weeks later, on January 3, 2005, on an embankment near Pierson Road and US131 in Montcalm County. Julia was 23 years old.

Dawson was convicted of premeditated first-degree murder in her death and sentenced to life in prison in December 2008.

In his appeal, Dawson argued that evidence of his past abuse and inappropriate treatment of Julia should not have been admitted during the trial. The judges’ opinion noted that it was “evidence of marital discord or control, which is relevant to show a motive for murder or as circumstantial evidence of premeditation and deliberation.” They noted that it also showed Julia’s intent to get a divorce, which was also relevant to the issue of motive.

The court disagreed with Dawson’s argument that the evidence was unfairly prejudicial. The opinion said that because the evidence was circumstantial, evidence of motive was highly relevant. For instance, evidence was presented that Dawson had previously been through a costly divorce and lost primary custody of his children, and stood to lose his and Julia’s son if she divorced him. The court said the evidence was relevant to show he had a motive to kill Julia and prevent the divorce, and without evidence of his controlling manner and treatment of her, the jury would not have been able to comprehend whether Julia was serious about seeking a divorce or whether she had reason to do so.

Dawson also accused the prosecutor of misconduct during closing and rebuttal arguments when he commented that Dawson killed Julia because it was “in his nature” and that was “the kind of guy he is.” The court noted that Dawson did not object to the prosecutor’s remarks at trial, and noted that the prosecutor’s comments need to be viewed in context. The court said that the record shows the prosecutor was arguing from the evidence that the Dawson had a motive and intent to kill Julia based on marital discord and his attempts to control her.

For a complete copy of the opinion, click here.