California, United States of America
The following excerpt is from People v. Valentine, 207 Cal.App.3d 697, 254 Cal.Rptr. 822 (Cal. App. 1988):
"Appellant concedes that a defendant's need for money may be relevant to show motive in a robbery case. Appellant also concedes if a defendant has a drug habit which requires expenditures beyond his means, then such evidence is logically relevant to prove motive under Evidence Code section 1101. (People v. Perez (1974) 42 Cal.App.3d 760, 767-768 [117 Cal.Rptr. 195].)" (Id. at p. 362, 184 Cal.Rptr. 186.)
However, the court concluded:
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