What is the test for admissible evidence of a defendant's prior criminal past?

Section 1101, subdivision (b), provides that evidence of a person's prior criminal act is admissible "'when relevant to prove some fact (such as motive, opportunity, intent, preparation, plan, knowledge . . .) other than his or her disposition to commit such an act.' . . . Moreover, to be admissible, such evidence '"'must not contravene other policies limiting admission, such as those contained in Evidence Code section 352.'"' [Citation.]" (People v. Avila (2006) 38 Cal.4th 491, 586-587.) "'On appeal, we review a trial court's ruling under Evidence Code section 1101 for abuse of discretion. [Citation.]' [Citation.]" (People v. Gray (2005) 37 Cal.4th 168, 202.)

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Here, defendant has not met his burden of establishing that the trial court abused its discretion when it allowed his 2005 and 2007 offenses to be introduced to prove the main issue of fact at trial, namely, his intent when he possessed a large quantity of prescription drugs which were not prescribed to him. Defendant contends his prior offenses were not sufficiently similar to the charged offense to support the inference that he harbored the same intent in each instance. Specifically, he argues that the officers' opinions that he "harbored an intent to sell illegal drugsdo not have any tendency in reason to demonstrate that [he] must have harbored the same intent when he was found, under entirely different circumstances, to be in possession of prescription drugs . . . while he was travelling in a car away from home with no cell phone or other known means of communication." In response, the People contend the facts of the prior offenses are sufficiently similar to the facts of the current offense. The similarities include possession of a large amount of cash in various denominations, along with possession of a large quantity of drugs that appeared to be packaged for sale. The People argue that "[w]hile the circumstances of the prior offenses and the current offense are not identical, when a prior offense is admitted for its relevance to prove intent, 'a distinctive similarity between the two crimes is often unnecessary for the other crime to be relevant.' (People v. Wilson (1991) 227 Cal.App.3d 1210, 1217, internal quotations omitted.)" We agree with the People.