(dissenting). The testimony of defendant’s sister regarding past acts allegedly performed on her by the defendant was inadmissible under MRE 404(b) and should have been excluded. The trial court made statements that indicated a misconception of this Court’s decision in People v VanderVliet, 444 Mich 52; 508 NW2d 114 (1993). I find the Court’s decision today to both evidence and encourage that and other misconceptions of the standard to be applied in instances of proffered “other bad acts” evidence under MRE 404(b). The testimony offered was extremely prejudicial to the defendant, and not admissible for any proper purpose.1
i
The defendant in this case was charged with multiple counts of criminal sexual conduct with an adopted daughter. The defendant and the complain*505ant’s mother also had two minor sons, and the allegations arose during a custody dispute regarding the two sons. In response to questioning by her mother, the daughter complained of sexual contact with the defendant.
The defendant went to trial, denying the allegations. The trial was, initially, to be a one-to-one credibility contest, with the defendant denying any sexual contact, the complainant claiming multiple incidents, and the trier of fact left to assess the credibility of the individuals. The prosecution, however, sought to introduce testimony of the defendant’s sister,2 that the defendant had engaged in multiple sexual activities with her years before, when she was a child. Such activities, including intercourse,3 were alleged to have continued for several years, until the sister became pregnant after her marriage.
The trial court, deciding the issue of admissibility, commented on the record that, although past Michigan precedent did not support the admission of this testimony, the court believed that VanderVliet “open[ed] the door considerably more,” and would allow for admission. The jury therefore was faced not with a one-to-one credibility contest, but, rather, with a parade of allegations of repulsive and horrific acts of incest totally unrelated to the case at hand.4
Lacking a coherent and substantial basis to support admission of this evidence, the majority instead *506undertakes a strained effort to extend what might arguably be a basis for a very limited line of questioning into a purported reason to admit wholesale every allegation against the defendant that the witness could present, regardless of how unrelated it might be to the charges at hand. I find this reasoning to be incorrect, even under the standard enunciated in VanderVliet. Further, I find it to be only a rather transparent attempt to reach a desired conclusion, with little consideration of the effect such a short-sighted endeavor might have on our law of evidence.
The test brought to us by VanderVliet is:
First, that the evidence be offered for a proper purpose under Rule 404(b); second, that it be relevant under Rule 402 as enforced through Rule 104(b); third, that the probative value of the evidence is not substantially outweighed by unfair prejudice; fourth, that the trial court may, upon request, provide a limiting instruction to the jury. [Id. at 55.]
MRE 404(b)(1) provides:
Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, scheme, plan, or system in doing an act, knowledge, identity, or absence of mistake or accident when the same is material, whether such crimes, wrongs, or acts are contemporaneous with, or prior or subsequent to the conduct at issue in the case.
Under the VanderVliet standard, the prosecution and the majority have failed to point to a proper pur*507pose under the first prong, and I therefore conclude that the evidence should not have been admitted.5
n
The majority finds that the sister’s testimony would have been admissible to rebut the defense theory of fabrication relating to the custody dispute, citing VanderVliet. Accepting the majority’s stated purpose, however, does nothing to lead me to a conclusion that the evidence should have been admitted. Rather, the purpose as stated by the majority clearly indicates that the great majority of the evidence admitted was neither necessary nor appropriate to achieve any proper purpose, and could only serve to inject into the proceedings the sort of prejudice MRE 404(b) specifically seeks to avoid.
Had the sister been permitted to testify that she told the mother about the alleged abuse suffered at the defendant’s hands immediately before the mother’s questioning of the victim, perhaps this testimony would have “corroborated” the testimony regarding the timing of the mother’s questions, or at least provided an inference of credibility for the mother. In view of the defendant’s attack on the mother’s credibility, this might have been permissible.6 This point, however, is the farthest the trial *508court could legitimately proceed in admitting evidence to support the testimony regarding the timing.
The remaining testimony regarding the various acts allegedly performed by the defendant on his sister, however, should not have been admitted. Such testimony corroborated only the testimony of the daughter regarding the abuse claimed by her, and did so only by the inference that even the majority agrees is prohibited by MRE 404(b), that the defendant acted in accordance with a propensity to commit such crimes.
With respect to this testimony, I tend to think that the so-called proper corroboration of the victim’s testimony is gained precisely by presenting the improper inference of criminal propensity to the jury. While the timing of the allegations by the sister might offer some insight into the reason the mother chose the particular moment she did to question her daughter, the testimony being corroborated by the substance of the allegations admitted into evidence is that of the abuse, not of the timing of the questions. The fact that there were allegations recently made supports the mother’s otherwise inexplicable decision to suddenly raise the abuse question with her daughter. Where this decision is subject to attack, such support is permissible. The substance of the allegations, however, as described in detail by the witness, and admitted by the trial court, does nothing to address this issue of timing, and serves only to suggest, inappropriately, that the defendant’s nature was one prone to deviant sexual acts.
*509Even if I were to agree with the evidence being admissible for this purpose, I would be compelled to apply the third prong of VanderVliet, an analysis of probative value versus unfair prejudice. I find the majority’s effort in this regard to be only a passing mention of the necessary test, with no sign of its application. Indeed, as noted, even if some evidence were admissible for this limited purpose, would it all be necessary? A rebuttal of the allegation concerning the timing of the mother’s questions to the victim could have been accomplished with no more than the admission of testimony regarding the sister having informed the mother of past abuse. This would have served to make the jury aware of the reason behind the mother’s questions, with no need for further specific allegations. Instead, the trial court allowed the daughter to testify about specific allegations at length. I find the majority too willing to stretch to meet the first prong of VanderVliet's test, and disagree with its apparent reduction of the third prong of the test to merely a restatement of the first prong.
The majority makes much of the distinction that the first prong of MRE 404(b) is “inclusionary” rather than “exclusionary.” Under this view, it is presumed that all purposes previously in existence or later invented are “proper purposes,” provided they do not fall within the prohibited category of evidence of criminal propensity. I do not purport to take issue with the various authorities who have spoken about this feature in regard to the similar federal rule of evidence. I do note, however, that this view arrives only lately to Michigan jurisprudence.7 More importantly, I *510note that the “inclusionary” nature as cited refers to the purposes, other than to suggest the impermissible character inference, not to the substance of the evidence itself. Whatever evidence is offered must be able to withstand an evaluation for a proper purpose, even under this “inclusionary” view. Only the evidence that actually serves such a purpose may be admitted.
In People v Engelman, 434 Mich 204; 453 NW2d 656 (1990), while the Court was unanimous in finding the admission of a photograph of the defendant, standing *511naked near a partially nude minor female, to have been erroneous when he was on trial for an unrelated charge of criminal sexual conduct with a young male, we split four to three on the rationale. Nonetheless, the majority’s opinion, cited for this proposition, found it necessary to exhaust the list of reasons found in the rule, but declined to search high and low for others, in finding the evidence not to be admissible for any proper purpose under existing precedent.
Therein, quite simply, lies my problem with the majority’s conclusion. Previously, we have required a proper purpose, regardless of the “inclusionary” nature of the rule, to be one that is acceptable on its own footing, rather than being merely a derivative of the disallowed purpose of showing propensity. The exceptions listed in the rule are well grounded and supported in our precedent. Indeed, many were created by statute long before the current Rules of Evidence were adopted.8 I therefore cannot agree with the idea that merely by acknowledging the rule’s nature, we must open the door to any evidence presented, without requiring that all such evidence admitted serve some purpose other than seeking to prove criminal propensity, regardless of how disgusting we might find such purported propensity. Where the majority refuses to truly acknowledge that in fact it is extending the scope of proper purposes under MRE 404(b) to apply in a fashion so as to permit a proper purpose for any single question to bootstrap into evidence the answers to all arguably related *512questions, no matter how irrelevant or prejudicial, I cannot agree.
The majority’s decision is not supported by the Michigan Rules of Evidence, our prior case law, or the facts of this case. The sister’s testimony was neither offered nor admitted for a proper purpose. I would find the trial court’s admission of the testimony to be error, and affirm the result of the Court of Appeals.9
Brickley and Kelly, JJ., concurred with Cavanagh, J.I dissented in VanderVliet, cautioning that our past decisions should not be lightly discarded, and that the standard articulated by the majority would offer new avenues of confusion for the courts below. Less than a year later, the trial court in this case stated, on the record, that it was surprised to see this Court’s decision in VanderVliet, “because that, to me, opens the door considerably more than under the cases we had previous to the time. If this motion had been made prior to the Vandervleet [sic] decision, this Court is convinced that it probably would not have admitted it.”
There is some dispute in the record whether the individual was the defendant’s sister or half-sister. For simplicity’s sake, she will be referred to as simply the defendant’s sister.
There were no charges of intercourse between the defendant and the complainant daughter.
Which is not to dispute the seriousness of the charges that were present in the instant case.
I pause to note that this evidence was also unnecessary. The trial judge indicated on the record that he believed the complainant’s testimony. The record reveals the testimony was quite credible and firm. There was no need for the prosecution to seek to introduce such prejudicial material as the sister’s testimony, or for the trial court to allow it, in order for a just result to be reached.
Note that the defendant’s attack on the victim’s credibility was derivative of his attack on the mother’s credibility. Both concerned the timing of the mother’s questions and the coinciding custody dispute. Hence, the *508proper purpose for which the sister’s testimony could have been allowable would be limited to those questions regarding timing.
In support of this statement, in People v Engelman, 434 Mich 204, 212-*510213; 453 NW2d 656 (1990), the majority offered citations of the treatises of McCormick, Evidence (3d ed), § 190, p 558, and 2 Weinstein, Evidence, ¶ 404[8], p 404-52, again, that both esteemed sources, as well as to a 1938 law review article that makes its return in the majority’s view here, Stone, The rule of exclusion of similar fact evidence: America, 51 Harv L R 988 (1938).
Of course, such historical inquiries are complicated by the various forms of the rules of evidence that have been subsequently adopted, as well as by VanderVliet’s purported usurpation of this area of law. Nonetheless, I too will journey back some sixty-plus years to find a telling reference previously cited as “enlightening” by this Court in People v Dean, 253 Mich 434, 437; 235 NW 211 (1931), where the Court found erroneous the admission of proof of sexual acts with persons other than the victim in a case similar to that at bar:
In crimes involving sexual offenses the courts have seemed readier to admit prejudicial evidence for such purposes as showing an “adulterous disposition.” But the whole problem of other crimes seems to be a matter of reaching a convenient balance between the necessity of obtaining proof and the danger of unfair prejudice. A relaxation in favor of admitting the evidence in this one situation, then, indicates that the courts are willing to give more weight to a criminal record of this sort. Unless we can admit a greater relevancy or a stronger social need of protection, there seems no fair reason for the distinction. Two recent cases show that it is being abandoned. [Note, Evidence—other crimes, 29 Mich L R 473, 480 (1930), citing Wentz v State, 159 Md 161; 150 A 278 (1930), and Doss v State, 156 Miss 522; 126 So 197 (1930) (emphasis in the original).]
It is unfortunate that the Court today returns to a predictable path based more on the nature of the crime alleged than on any “fair reason.”
See, e.g., People v Dean, n 7 supra, construing 1927 PA 175, ch 8, § 27 (Code of Criminal Procedure), 1929 CL 17320; MCL 768.27; MSA 28.1050, which lists purposes substantially identical to those found in MRE 404(b).
There being no proper purpose for the evidence to be admitted under MRE 404(b), I need not proceed to an analysis of the probative versus prejudicial nature of the testimony. I note however, that the majority seems to do no more in this area than mention the prong regarding it. Under the majority’s view, it seems a proper purpose is sufficient to carry the evidence past any prejudicial weighing, despite the requirement that such a factor be considered.
I also note that while I dissented in VanderVliet, and find the confusion of the trial court in this case to support my view that the majority’s decision in VanderVliet was both unwise and unnecessary, it is not those concerns that move me to write today. Rather, in the majority’s view today, I see an evisceration of the test of VanderVliet, and its reduction to a mere conclusory formality, wherein appellate courts will not have an appropriately limited role, but no functional role whatsoever preventing the erroneous admission of irrelevant and prejudicial evidence.