Find the number of outcomes in the complement of the given event.

Out of 287
books in a bookcase, 188
are fictional.

Since the complement of the event "books that are fiction" includes all books that are not fiction, we need to find the number of outcomes in the complement by subtracting the number of fiction books from the total number of books.

Total number of books = 287
Number of fiction books = 188

Number of non-fiction books = Total number of books - Number of fiction books
Number of non-fiction books = 287 - 188
Number of non-fiction books = 99

Therefore, there are 99 outcomes in the complement of the event.