How have courts treated "character and conduct" as an aggravating factor in a sexual assault case?

Devier v. State (1984) 253 Ga. 604, 323 S.E.2d 150, 163 [allowing as an aggravating factor "[a]ny lawful evidence," including prior unadjudicated acts, that tend to show a defendant's "general

[475 P.3d 1115]

moral character" or "predisposition to commit other crimes"]; State v. Johns (Mo. 2000) 34 S.W.3d 93, 113 [allowing consideration of evidence of defendant's "character and conduct," including unadjudicated criminal conduct that occurred before or after the

[271 Cal.Rptr.3d 437]