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Name: People v. Williams
Case #: C081267
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 05/15/2018
Summary

Murder conviction reversed where evidence that defendant committed a prior attempted murder during a domestic dispute was erroneously admitted to prove his intent to kill his current wife. In 2014, Williams stabbed his wife in the neck and left her to bleed to death. The trial court permitted the prosecution to introduce evidence of Williams’ 1992 conviction for shooting his then mother-in-law when she attempted to intervene in a domestic dispute he was having with his estranged former wife. Williams was convicted of first degree murder. On appeal he challenged the admission of the other crimes evidence. Held: Reversed. No evidence is admissible except relevant evidence (Evid. Code, § 350), i.e., evidence having a tendency in reason to provide or disprove a disputed fact. As a general rule, prior crimes evidence is inadmissible to prove the defendant had the propensity to commit the charged offense. Other crimes evidence may be admissible to prove some fact other than criminal disposition, like motive, plan, intent, etc., if it has substantial probative value. Even if relevant for some non-character purpose, other crimes evidence may be excluded where its admission creates the substantial danger of undue prejudice (Evid. Code, § 352). Here, the dissimilarity of the two events was so great that the evidence of the prior crime had little or no tendency in reason (Evid. Code, § 210) to reflect on Williams’ mental state during the 2014 killing. Any probative value was outweighed by the prejudicial effect of the evidence, which was heavily relied upon by the prosecution.

The full opinion is available on the court’s website here: http://www.courts.ca.gov/opinions/documents/C081267A.PDF