In one form, an apparatus includes a memory controller. The memory controller includes a command queue and an arbiter. The command queue receives and stores memory access requests. The arbiter picks the memory access requests from the command queue based on a plurality of criteria, and provides picked memory access requests to a memory channel. The arbiter includes a streak counter for counting a number of consecutive memory access requests of a first type that the arbiter picks from the command queue. When the streak counter reaches a threshold, the arbiter suspends picking requests of the first type and picks at least one memory access request of a second type. The arbiter provides the at least one memory access request of the second type to the memory channel.