State v. Patterson

Summary

The court affirmed the defendant’s murder convictions, holding that the trial court properly admitted evidence of two prior shootings to establish means and identity. The defendant’s challenge to the scientific reliability of the firearm-identification testimony was not reviewable because he had not requested the required foundational hearing, and the evidence was relevant under the broad relevance standard. The prior-shooting evidence’s probative value outweighed its prejudicial effect because the trial court strictly limited the evidence and repeatedly instructed the jury on its permissible uses.