State v. Marcello E.

Summary

The court held that the trial court abused its discretion by admitting two prior incidents in which the defendant assaulted the victim to prove specific intent. Even assuming the evidence was relevant, its limited probative value was outweighed by its prejudicial effect because intent was already established, identity was the central disputed issue, and the evidence effectively suggested that the defendant committed the charged stabbing. The court further held that the error was harmful because the identity evidence was equivocal and limiting instructions did not cure the prejudice, requiring reversal and a new trial. Mullins, C. J., joined by Dannehy, J., dissenting, would have found the error harmless because the state's identification evidence was strong and the prior incidents played a limited role.