Is evidence of a similar crime admissible if relevant to prove the material fact at issue?

California, United States of America


The following excerpt is from People v. Navarro, F065680 (Cal. App. 2015):

Thus, evidence of other crimes is admissible if relevant to prove a material fact at issue, separate from criminal propensity. (People v. Daniels (1991) 52 Cal.3d 815, 856.) "In order to satisfy the requirement of materiality, the fact sought to be proved may be either an ultimate fact in the proceeding or an intermediate fact 'from which such ultimate fact[] may be presumed or inferred." (People v. Thompson (1980) 27 Cal.3d 303, 315.) "Evidence of an uncharged offense offered to prove an intermediate fact is not necessarily material. The materiality requirement is satisfied only if the intermediate fact tends logically and reasonably to prove an ultimate fact which is in dispute." (Id. at p. 315., fn. 14.)

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