What is the test for evidence of a past crime to show a plan common to the present crime?

California, United States of America


The following excerpt is from People v. Evans, C051782 (Cal. App. 10/17/2007), C051782 (Cal. App. 2007):

Evidence of a past crime to show a plan common to the present crime is admissible if there are "striking similarities" between the two crimes. (People v. Scheer (1998) 68 Cal.App.4th 1009, 1020.) In other words, evidence establishing a design or plan must show a concurrence of common features that the various acts are naturally to be explained as caused by a general plan. (People v. Ewoldt (1994) 7 Cal.4th 380, 393-394.)

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