What is the test for admitting a prior voluntary manslaughter conviction?

Defendant contends the admission of his prior voluntary manslaughter conviction violated his Fourteenth Amendment due process rights, in that it "rendered his trial fundamentally unfair." He makes this argument both with respect to admission of the prior conviction as a predicate offense and with respect to admission of the prior conviction to show intent and motive. However, since we have not found that admission of the prior conviction evidence was error under state law, we need not decide "the consequences of that error, including . . . whether the error was so serious as to violate due process." (People v. Partida (2005) 37 Cal.4th 428, 437.)

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