State v. Patterson

Summary

The court affirmed the defendant’s convictions for two murders, holding that the trial court properly admitted evidence of two prior shootings involving the same firearm to establish means and identity. The defendant could not use a relevance challenge on appeal to obtain review of the scientific reliability of the firearms expert’s methodology because he had not requested the required pretrial reliability hearing. The court also held that the evidence’s probative value outweighed its prejudicial effect because the trial court narrowly limited the evidence and repeatedly instructed the jury regarding its permissible use.