Every system of criminal law that tries people by jury has had to answer the same question about the killer with more than one victim. If the prosecution can prove only one death to the standard a verdict requires, may it also tell the jury about the others? The jurors will learn that the accused is thought to have done it before, and they will find that very hard to forget. The traditional answer is no, if the point is only that he is the sort of person who does such things. The traditional exception is yes, if the earlier or later death proves something that is genuinely in dispute: that this death was no accident, that the same person did it, that the act was planned. The exception has produced a rule with a different name in nearly every jurisdiction, and in every one of them judges have learned that the line between pattern and propensity is easier to state than to draw.
What follows are nine cases from six jurisdictions in which a court had to draw it. In some, the other deaths were put before the jury though the accused had never been tried for them. In a few, they were kept out. In the case of Marybeth Tinning, the deaths in question were those of two sons she was never charged with killing.
Sarah Jane Makin was a Sydney midwife and the wife of John Makin, a former brewery drayman. In the early 1890s the couple took in infants for money, most of them the children of unmarried mothers who could not keep them. In October 1892 the deaths of two babies came to light in Macdonaldtown, in inner Sydney, at a property the family had recently left. Police went on to search the properties the Makins had rented since 1890, and by the count in the Australian Dictionary of Biography the deaths of 13 infants came to light; ABC News and the Illawarra Mercury give the total as 15. Most of the infants were never identified. How any of the children died was never determined, according to SBS News.
Sarah and John Makin were tried together in March 1893 for the murder of a single child. SBS News gives the child as Horace Murray; the Australian Dictionary of Biography records the verdict as the murder of an unknown infant. Both defendants were convicted. The jury recommended mercy for Sarah, and while John was executed at Darlinghurst Gaol in August 1893, her death sentence was commuted to penal servitude for life. She served about 18 years, was released on April 29, 1911, on grounds of great age and failing health, and died at Marrickville in 1918. The other infants were never the subject of separate convictions.
The Makins' appeal to the Judicial Committee of the Privy Council failed, and the decision, Makin v Attorney-General for New South Wales, became the starting point of the common-law rule on what lawyers call similar fact or propensity evidence. In 1977 the McGill Law Journal described it as "the landmark decision" on the subject, and argued that the examples given in the judgment hardened over time into a list of fixed categories, such as absence of accident, motive and identity. Wendy Harris traced its later treatment by the High Court of Australia, which in cases such as Hoch v R (1988) and Pfennig v R (1995) moved toward a test that asks whether the evidence, if accepted, has any reasonable explanation other than the guilt of the accused. In New South Wales, Ian Barker QC wrote, the common-law rule that began with Makin was replaced by the tendency and coincidence provisions of the Evidence Act 1995.
The case has had its critics. Annie Cossins, a law professor at the University of New South Wales, published a book on the Makins, The Baby Farmers, in 2013, and in the same year an article in the Sydney Law Review titled "The Legacy of the Makin Case 120 Years on: Legal Fictions, Circular Reasoning and Some Solutions." SBS News summarized her view that the trial was unfair and that the evidence was lacking.
George Joseph Smith was executed at Maidstone Prison in Kent on August 13, 1915. A jury at the Central Criminal Court in London, the Old Bailey, had convicted him of murdering Bessie Mundy, who died suddenly in 1912 while married to him under a false name. He was tried for her death alone. At that trial the prosecution was also allowed to put before the jury the deaths of two later wives, Alice Burnham in 1913 and Margaret Elizabeth Lofty in 1914, each of whom had also died suddenly, in the same circumstances, soon after marrying him. Those two deaths were admitted as similar-fact evidence, to show a pattern. Smith was never tried for them, and they are not convictions. Popular accounts that say he was convicted of three murders, or tried for all three, overstate the record.
Smith, who was born in 1872, was a bigamist and forger who married at least eight times under a series of names. Alice Burnham married him in 1913, according to Andrew Maunder, and died the same year at a boarding house in Blackpool on the Lancashire coast. The Camden New Journal says she was on her honeymoon there. Her father had distrusted Smith from the start. Margaret Lofty, 38, died on December 18, 1914, at Highgate, in north London. An inquest followed. Maunder gives the verdict as death by misadventure; the Camden New Journal says the coroner recorded accidental death, probably after an epileptic seizure. The Camden New Journal says Smith cashed a life insurance policy worth 700 pounds within a week, while Maunder says he was arrested at the solicitor’s office where he had gone to collect the 700 pounds.
The magazine History Today sets out the pattern the prosecution relied on. Each woman had made Smith her beneficiary, either in a will or through a life insurance policy. He moved each one to a town where she knew nobody, told a local doctor that she had a health problem, and then appeared distraught when she died. The case turned on a newspaper. A father read a report of a London bride who had died suddenly and recognized the death of his own daughter a year earlier. The pathologist Bernard Spilsbury gave evidence that the deaths were not accidents, and the case is closely tied to his name.
Smith was sentenced to death on July 1, 1915, and appealed. Kamraj Nayagam describes the reported appeal decision, R v Smith, [1914 to 1915] All ER Rep 262, as short and as largely adopting the principle already laid down in Makin. The appeal failed despite the efforts of the defense counsel, Marshall Hall, and the case stays, in Nayagam’s phrase, the most well known of the English cases on the point and a fixture in textbooks. Marshall Hall’s suspicion that Smith had used hypnotism is reported as a private belief, not a finding. The accounts differ on small points: the victim’s surname is Mundy in most sources and Munday in Nayagam’s; Smith was 45 when executed, according to History Today, but 41 at the time of the Highgate death, according to the Camden New Journal, and the two figures do not agree.
Smith and Makin supply the first chapters of the rule in the English-speaking world, one from a colonial court of 1893 and one from the Old Bailey in 1915.
Aileen Wuornos was convicted of murdering six men she had met in Florida between late 1989 and late 1990, and she confessed to killing a seventh, Peter Siems, but was never charged in his death. The men were middle-aged and mostly strangers to one another. Each had given her a ride. She was arrested on January 9, 1991, and indicted in Volusia County on January 28, 1991, for the murder of Richard Mallory, 51, of Clearwater, and for armed robbery.
The central ruling at her first trial came on January 17, 1992. Over defense objections, Judge Uriel Blount allowed the state to present evidence of the other killings under Florida’s Williams rule, which admits evidence of similar crimes when they tend to prove something in dispute, such as intent. Tanner argued for the prosecution that the other killings showed Wuornos meant to rob and kill, not to defend herself. "We don’t try people on propensity, we don’t try people on their character," her lawyer, Nolas, answered. Witnesses described the deaths of Charles Richard Humphreys, Troy Burress, David Spears, Charles Carskaddon and Walter Antonio and the death of Peter Siems. On January 21, Siems’s son, then 24, an engineer from Arkansas, identified a pair of scissors, a shaving kit, a jacket, suitcases and a license plate from his father’s car. "If I remember right, these are the scissors my father used to use to cut my hair," he said. As he left the stand, Wuornos told her lawyers there was "lie after lie after lie." Two men testified about encounters with Wuornos in 1990; one, a truck driver, said she had threatened him with a gun in November 1990. The jury saw an edited portion of her videotaped confession dealing only with Mallory.
Wuornos was the only defense witness. She testified for about three hours, telling the jury that Mallory had tied her up, assaulted her and threatened to kill her, and that she killed him when he came at her again. She said she had not told investigators about the assault and had confessed to clear her companion, Tyria Moore. "Everyone has the right to defend themselves," she said. The defense rested on January 24, and the jury returned a verdict of guilty of first degree murder on January 27. After a recommendation of death, Judge Blount sentenced her on January 31.
What the jury did not hear shaped the case as much as what it did. It never learned that Mallory had served about ten years in a Maryland institution after a 1957 sexual offense; a television producer discovered the record ten months after the verdict, the St. Petersburg Times reported in October 1992. The Williams rule let in five other deaths, while a fact bearing on her claim of self-defense stayed outside.
She did not face a guilt-phase jury again. On March 31, 1992, she pleaded no contest to the murders of Humphreys, Burress and Spears in Marion and Citrus counties; on June 22, 1992, she pleaded guilty in Pasco County to the murder of Carskaddon; and she pleaded guilty to the murder and armed robbery of Antonio in Dixie County. She received six death sentences in all, which the Florida Supreme Court affirmed in four opinions between 1994 and 1996. In 2001 she told a circuit judge that she had killed the men to rob them. "I killed those men in the first degree, robbed and killed them," she said, and she said she had lied at her trial to beat the system. She was ruled competent to drop her appeals on July 20, 2001, and the Florida Supreme Court approved on April 1, 2002. She was executed at Florida State Prison and pronounced dead at 9:47 a.m. on October 9, 2002, aged 46.
Rory Enrique Conde confessed in June 1995 to six killings in Miami, from September 1994 to January 1995. They had been the subject of a Metro-Dade police task force, an FBI profile and a public hunt. Conde was caught not through that hunt but through a separate case: a kidnapping investigation in June 1995 led police to him, and he was arrested about noon on Saturday, June 24, and confessed the next day, according to the Florida Supreme Court. He was 30, according to United Press International. A grand jury indicted him on July 12, 1995, on six counts of first-degree murder: Lazaro Comesana, Elisa Martinez, Charity Nava, Wanda Crawford, Necole Schneider and Rhonda Dunn.
The legal fight was over how many of the six the jury at any one trial should hear about. The defense had first asked for separate trials. When the trial court ruled that the State could present evidence of the other five killings at the Dunn trial anyway, under Florida’s Williams rule on similar crimes, the defense reversed course and asked to have all six counts tried together. The trial court agreed. The State appealed, and in 1999 the Third District Court of Appeal held that putting the counts back together was an abuse of discretion, because the murders were not connected closely enough in time, place or manner to be tried jointly. The appeals court said the offenses, though similar, were separate episodes that required separate trials (State v. Conde, 743 So. 2d 78).
The result was a trial on one count with evidence of the other five admitted as proof. The jury heard about all six killings. The State argued that the other five were needed to prove identity, intent and premeditation, because the defense contested premeditation. Its list of similarities included that each death occurred late at night within a small area, that physical evidence tied many of the deaths to him, and that a message had been left with the third victim. At oral argument on appeal the State said it had kept that evidence narrow, with few witnesses and few or no graphic photographs. The evidence on the Dunn count itself included DNA, fiber, tire and shoe evidence, medical testimony and the confession. The State used the medical examiner’s evidence to argue that the killing took time and was premeditated.
On October 19, 1999, the jury convicted him of the first-degree murder of Rhonda Dunn, and on March 7, 2000, he was sentenced to death. On September 4, 2003, the Florida Supreme Court affirmed the conviction and sentence in an unsigned opinion (Conde v. State, 860 So. 2d 930). It held that the evidence of the other killings was relevant to identity, intent and premeditation and had not become an improper feature of the trial. It held that his confession was direct evidence of premeditation and, together with the medical testimony and the pattern of the earlier killings, showed he had time to reflect. It held the confession voluntary. It identified errors in admitting the detective’s warnings to Dunn and testimony about the arrest, and in excluding a chaplain, but held each harmless. It rejected his claim under Ring v. Arizona, the 2002 United States Supreme Court decision requiring juries to find the facts that make a defendant eligible for death. Chief Justice Anstead agreed with the conviction but dissented in part: because the judge alone had decided the two aggravating factors he called two of the most serious, he wrote, the death sentence violated Ring.
The other five counts followed. On April 3, 2001, Conde was sentenced to life imprisonment on the five other first-degree murder counts of the 1995 indictment, according to the Florida Commission on Capital Cases. A separate case from April 1995 had ended on February 13, 1998, with a sentence of 18 years and 10 months. Postconviction relief on the Dunn count was denied, and the Florida Supreme Court affirmed on February 11, 2010. A federal habeas petition was filed on June 7, 2010, and was pending in July 2010; no later outcome is reported.
Paul Durousseau is serving life in prison without parole for one murder: the killing of Tyresa Mack, a 24-year-old mother of three, in Jacksonville, Florida, on July 26, 1999. He was not charged in that case until four years later. In June 2003 a Duval County grand jury indicted him for the deaths of five other young women in Jacksonville between December 2002 and February 2003, a period when he had briefly driven a cab. Detectives then reopened Mack’s unsolved case, and he was arrested for it on August 26, 2003, and indicted on September 4.
The case took almost four years to reach trial. Before it began, prosecutors asked to put evidence of two of the 2003 deaths, those of Nikia Kilpatrick and Shawanda McCallister, before the Mack jury, under Florida’s Williams rule, to prove identity and premeditation. The two cases were chosen from the five to keep the trial manageable. After a hearing on June 28, 2006, the trial court ruled the evidence admissible, and the judge gave the jury limiting instructions when it came in and again at the close of the case. The state argued that the three deaths shared a pattern: young women of similar build, the same cause of death, and his DNA on or near each of them. His fingerprints were not at any of the locations. The defense replied that the similarities were general, not unique, and pointed to differences described by a defense medical expert. It also argued that the state had not proved by clear and convincing evidence that he had committed either of the other two killings.
Jury selection began on May 22, 2007, and the trial on May 23. Over about two weeks the jury heard dozens of witnesses. The day before the case went to the jury, Durousseau testified for about 90 minutes. He admitted having sex with Mack, Kilpatrick and McCallister shortly before each of them died, and he denied killing any of them. He admitted he had first lied to detectives by saying he did not know any of the women. Asked on cross-examination whether his sex life kept being interrupted, he answered, "It all depends on what you mean," before agreeing. The jury convicted him of Mack’s murder on June 8, 2007. On December 13, 2007, Circuit Judge Jack Schemer sentenced him to death on the jury’s 10 to 2 recommendation.
In November 2007 the State Attorney’s Office dropped the five remaining Duval County murder charges, in the court term a nolle prosequi. News4Jax reported that prosecutors feared an acquittal in any of those cases could put the Mack conviction at risk, and that if the Mack conviction were ever overturned, it could cause problems for the remaining cases. Durousseau was never tried for the deaths of Nichole Williams, Nikia Kilpatrick, Shawanda McCallister, Jovanna Jefferson or Surita Cohen. In 2003 he had also been charged in Georgia with the 1997 death of Tracy Habersham in Columbus, and in December 2007 he was expected to face trial there; no Georgia trial or verdict has been reported.
On December 9, 2010, the Florida Supreme Court affirmed the conviction and the death sentence. The majority held that the trial judge had not abused his discretion in admitting the collateral-crime evidence, which was relevant to identity and premeditation; that the similarities were sufficient; that the gap of about three and a half years between Mack’s death and the later killings did not make the evidence unreliable; and that the evidence had not become a feature of the trial. Justice Pariente dissented, joined by Justice Quince. She wrote that the trial court had never made a finding of clear and convincing proof that Durousseau committed the collateral crimes, and had instead relied on the similarity between the crimes, a kind of bootstrapping she said the law did not allow. In her view the evidence in the McCallister case was strong enough on its own, but the Kilpatrick evidence, which showed that he had had sex with her shortly before her death, had been in the area and had denied knowing her, did not meet the standard. She concluded that its admission was harmful because the state had used the similarities to argue that the deaths were no coincidence. A motion for rehearing was denied on February 21, 2011.
The sentence did not survive. On January 31, 2017, the Florida Supreme Court vacated it under Hurst v. Florida and ordered a new penalty phase. A second jury also voted 10 to 2 for death, but on December 10, 2021, Durousseau was resentenced to life in prison without the possibility of parole. In May 2023 he was held at Walton Correctional Institution at DeFuniak Springs. The collateral-crime evidence in the Mack case had been admitted over a dissent that would have excluded part of it, and the five prosecutions it was drawn from were never brought to trial.
Diane Odell was a mother of eight living children when, in May 2003, the deaths of three more of her children came to light in Safford, Arizona. The three had been born in secret and unattended in Kauneonga Lake, in the town of Bethel in Sullivan County, New York, between 1982 and 1985; the courts give those years, while an Arizona prosecutor gave 1981 to 1984. No one outside the family had known she was pregnant. She told police the babies died shortly after birth. She was 49 when she was arrested that May and arraigned in New York on three counts of murder.
The main pretrial dispute concerned a fourth, earlier infant, born in 1972, whose death came to light in Bethel in March 1989. No one alleged a crime in that birth or death, and the prosecution had accepted an innocent explanation for it. Even so, the prosecution asked to tell the jury about the 1972 birth and the 1989 discovery as part of its main case, arguing under the Molineux rule, New York’s rule on other-acts evidence, that the earlier events showed a common scheme or plan. On December 3, 2003, Sullivan County Judge Frank J. LaBuda refused. He ruled that the 1972 facts had some probative value, but that their prejudicial effect on the jury would be so overwhelming that no limiting instruction could cure it. If the prosecution believed that death was criminal, he wrote, it could seek to add a murder count. He left open the possibility that the evidence might come in later if the defense raised the point itself, or for cross-examination.
The prosecution asked him to reconsider. He heard oral argument and on December 8, 2003, denied the motion again, holding that the evidence would be highly prejudicial even with repeated limiting instructions. He also doubted that the 1989 discovery amounted to a prior uncharged crime at all, though he assumed for argument’s sake that it did.
The trial went forward on the three deaths charged. The indictment also carried intentional murder counts, but the convictions in December 2003, after about four hours of jury deliberation, were on the three counts of murder in the second degree under the depraved indifference theory. On January 27, 2004, Judge LaBuda sentenced her to concurrent terms of 15, 20 and 25 years to life. The Appellate Division, Third Department, affirmed the convictions on February 2, 2006. At sentencing she maintained that she had not killed the babies. The ruling in her case is a useful counterweight to the Florida cases: the rule that let a jury in Florida hear about five other deaths kept a jury in New York from hearing about a death that no one alleged was a crime.
Marybeth Tinning was convicted in July 1987 of murdering her daughter Tami Lynne, who was four months old and died on December 20, 1985, in Schenectady, New York. A jury convicted her of murder in the second degree under the theory of depraved indifference to human life, while acquitting her of intentional murder. She was sentenced on October 1, 1987, to 20 years to life.
She was tried for one death. Tami Lynne was the ninth of Tinning’s children to die young, between January 1972 and December 1985. The eight before her had died between January 1972 and March 1981, and their deaths were recorded at the time as natural or unexplained. After questioning that began on February 4, 1986, she gave police a written statement. In it, UPI reported, she admitted causing the deaths of Tami Lynne and of two of her sons, Timothy, who died on December 10, 1973, and Nathan, who died on September 2, 1975, and wrote that she did not do anything to five of the others. She was never charged in any death but Tami Lynne’s. At her trial she said the statement had been obtained improperly, and in later years she told the parole board that she had killed Tami Lynne but had not harmed any of the others.
The two boys' deaths were thus admissions without charges. The statement is the only source for the claim that she caused them, no court ever ruled on those deaths, and the jury, which acquitted her of intentional murder, convicted her only of the death it was asked to decide.
Tinning served 31 years. The parole board denied her release in 2007, 2009, 2011, 2013, 2015 and 2017, and granted it after a hearing on July 10, 2018; she was released from Taconic Correctional Facility on August 21, 2018. The Daily Gazette later reported that she had been discharged from parole supervision. Her status since then has not been reported.
Shelly Andre Brooks was 37 when Wayne County prosecutors charged him in 2006 with killing seven women in Detroit over five years. The Wayne County prosecutor, Kym Worthy, called him "a quintessential serial killer" when the charges were filed, according to United Press International. Police had arrested him on July 30, 2006, after a tip from a woman who survived. Juries convicted him of first-degree murder in two of the deaths, at two Wayne County trials in 2007, and he received life in prison without parole on each, as Michigan requires.
The appeal that survives is from the first of those cases, decided by the Michigan Court of Appeals in an unpublished opinion dated June 24, 2008. It raised two issues, and the first concerned the other women. Under Michigan Rule of Evidence 404(b), evidence of other acts cannot be used to show that a defendant has a bad character, but it can be admitted for other purposes, such as intent, motive or a common scheme. In statements to detectives, according to the court, Brooks had described harming six other women besides the victim in the appealed case: five of them died, and one survived. The prosecution moved to admit evidence about those six women and about a further woman’s death. The trial court admitted the evidence about the six and excluded the further case.
Brooks argued that the evidence of the other women should not have been admitted. The panel held that the evidence was offered for proper purposes, intent, motive and scheme, and that the events were similar enough to be relevant. It held that the danger of unfair prejudice did not substantially outweigh the evidence’s value, especially since the jury had been instructed not to use it as character evidence. Such a decision, the court wrote, "is within the trial court’s discretion and will only be reversed where there has been a clear abuse of discretion."
The second issue was the statements themselves. Brooks asked the court to suppress them as involuntary. In Michigan, a hearing on that question is called a Walker hearing. He claimed that he had been interrogated over and over, that two officers had threatened him with violence, and that he had been taken out of jail for questioning every day for a month, sometimes for twelve hours or more. He also said he had asked for a lawyer. The panel went through the trial court’s findings: the rights forms signed before each session, the corrections he made, his ability to communicate, his prior experience with police, the absence of injury, illness or intoxication, and the jail records that did not match his account. "The trial court’s findings were not clearly erroneous," the court held. The conviction was affirmed.
Brooks was never tried for the six other women, and the other charges from 2006 were not pursued in court. As of January 2025 the Associated Press reported that he was serving his sentences.
Jeremy Skibicki, a Winnipeg man, was convicted in July 2024 of the first-degree murders of four First Nations women: Ashlee Shingoose, 30, Morgan Harris, 39, Marcedes Myran, 26, and Rebecca Contois, 24. Police said they were killed in Winnipeg between mid-March and mid-May 2022. Skibicki, then 35, was arrested on May 18, 2022, and charged with the first-degree murder of Contois; three further first-degree murder charges were laid on December 1, 2022. He admitted the four killings in a long police interview. At his trial he did not deny that he had caused the deaths. His lawyers argued that he was not criminally responsible because of a mental disorder. Chief Justice Glenn Joyal of the Manitoba Court of King’s Bench rejected that argument, ruled that the killings were planned and deliberate, and said Skibicki had acted on racist views.
On March 14, 2024, the defense had first told the Crown that it planned to call expert evidence. On May 1 it confirmed in court that it would argue Skibicki was not criminally responsible, and on May 2 it gave prosecutors an expert opinion. On Monday, May 6, defense lawyer Leonard Tailleur told the court that Skibicki admitted unlawfully causing the deaths of all four women. Crown prosecutor Chris Vanderhooft called this a new development. With the killings no longer in dispute, the Crown dropped its opposition to a judge-alone trial, saying it was "the best route to making sure this matter proceeds," and the jury was dismissed. The question for the court became Skibicki’s mental state and intent. Under Canadian law the burden of proving that he was not criminally responsible fell on the defense, on a balance of probabilities. The Crown and the defense also agreed that similar fact evidence could be used, and the Crown relied on it to show intent and capacity.
Skibicki’s case differs from the others in one respect that matters: all four deaths were charged in the same trial, and the parties agreed on the use of one to illuminate the others. There was no contest over admission. The question was what the evidence of four planned killings showed about a mind that the defense said was disordered. The judge’s answer was a verdict on July 11, 2024, of first-degree murder on all four counts. On August 28, 2024, Skibicki was sentenced to four life terms, served concurrently, with no parole eligibility for 25 years.
The rules differ in their names and in their tests, and the cases show it. In England and New South Wales the starting point was a judgment of the 1890s that became a catalogue of categories; in Florida it is the Williams rule, which allowed five other deaths to be described at Wuornos’s first trial and two at Durousseau’s; in New York it is Molineux, which in Odell’s case kept out a death that no one called a crime; in Michigan it is Rule 404(b), applied to six women in Brooks’s case; in Canada, in the Skibicki trial, the parties simply agreed. In Australia the rule has since been refined and, in New South Wales, replaced: the High Court moved to a test of whether there is any reasonable explanation other than guilt, and New South Wales replaced the common law with statute.
The people whose other deaths were used were often never tried for them. Smith was convicted of one murder and never tried for the deaths of the other two wives. Makin was convicted of one infant’s death among more than a dozen. Durousseau faced a jury for one of six women; Brooks for two of seven; Tinning for one of nine children. Their appeals did not turn on that fact alone. They turned, case by case, on whether the evidence proved something in dispute or merely suggested a person capable of it, and appeal judges split on the answer: Justice Pariente, in the Durousseau dissent, thought Florida’s own standard had been bypassed by reasoning from the similarities.
• October 1892: the deaths of two infants come to light in Macdonaldtown, Sydney; police search the Makin family’s earlier properties.
• March 1893: Sarah and John Makin are convicted in Sydney of the murder of one infant.
• August 1893: John Makin is executed; Sarah’s sentence is commuted to life.
• 1912 to 1914: Bessie Mundy, Alice Burnham and Margaret Lofty die suddenly soon after marrying George Joseph Smith.
• June 1915: Smith is tried at the Old Bailey for the death of Bessie Mundy only.
• July 1, 1915: Smith is sentenced to death; he is executed at Maidstone on August 13, 1915.
• December 1985: Tami Lynne Tinning dies in Schenectady.
• July 17, 1987: Marybeth Tinning is convicted of murder in the second degree (depraved indifference).
• January 17, 1992: Judge Blount rules that evidence of the other killings may go before the Wuornos jury; the verdict follows on January 27 and the sentence on January 31.
• June 24, 1995: Rory Conde is arrested; he confesses the next day.
• 1999: the Third District Court of Appeal rules that the six Conde counts cannot be tried together; October 19, 1999: Conde convicted of the Dunn murder.
• May 2003: the deaths of three Odell infants come to light in Arizona; December 3 and 8, 2003: Judge LaBuda refuses to admit evidence of the 1972 infant.
• December 2003: Diane Odell is convicted on three counts of second-degree murder.
• June 2006 to June 2007: the Williams rule hearing (June 28, 2006) and the Durousseau trial (verdict June 8, 2007).
• November 2007: the five other Durousseau murder charges are dropped.
• June 24, 2008: the Michigan Court of Appeals affirms Brooks’s conviction.
• December 9, 2010: the Florida Supreme Court affirms Durousseau’s conviction and sentence, with two justices dissenting.
• July 11, 2024: Skibicki is convicted of four counts of first-degree murder.
• August 28, 2024: Skibicki is sentenced to four concurrent life terms.