California, United States of America
The following excerpt is from People v. Harvey, B245606 (Cal. App. 2014):
Absent a defense request, the trial court generally has no duty to instruct on the limited admissibility of evidence. (People v. Valdez (2012) 55 Cal.4th 82, 139.) In an "extraordinary case", such evidence "might be so obviously important to the case that sua sponte instruction would be needed to protect the defendant from his counsel's
Page 15
inadvertence." (People v. Collie (1981) 30 Cal.3d 43, 64.) This is not that extraordinary case. Inasmuch as defendant was identified by multiple eye witnesses and made a number of incriminating statements during recorded telephone calls, the gold chain evidence was not particularly important to the case. As it turned out, the trial court belatedly gave a modified version CALCRIM No. 375 as it related to evidence of each charged crime as tending to prove the other charged crimes. (See, Discussion, Part A, ante.) The jury clearly understood the notion of limited admissibility of evidence, and the trial court had no sua sponte duty to give a CALCRIM No. 375 instruction specifically tailored to the gold chains found in defendant's room.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.