v. Williams

Summary

The court affirmed the reversal of Williams’s conviction because the district court improperly admitted evidence of Williams’s prior cocaine sale under CRE 404(b). Although the court rejected the court of appeals’ categorical limitations on modus operandi and common-plan evidence, it held that the prior transaction had little incremental probative value and created a substantially greater danger of unfair prejudice. The court also held that the error was not harmless because the informant’s credibility was central to the prosecution’s case.