The following excerpt is from People v. Hudy, 535 N.E.2d 250, 538 N.Y.S.2d 197, 73 N.Y.2d 40 (N.Y. 1988):
Whether prior crime evidence is actually being offered to prove propensity alone is often a subtle matter in which semantics sometimes plays an important part. For example, we recently held in People v. Lewis (supra) that evidence of prior sexual contact with the same "victim," traditionally admitted under the rubric of "amorous design," was really no more than a form of propensity evidence hiding behind an assumed name and should no longer be permitted. A similar analysis applies here.
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