State v. Marcello E.

Summary

The court held that the trial court abused its discretion by admitting two prior incidents of physical misconduct to prove the defendant's intent because the evidence's limited probative value was outweighed by its prejudicial effect. The error was harmful because identity was the central disputed issue, the prior misconduct repeatedly resurfaced and implicitly linked the defendant to the stabbing, and the remaining identification evidence was equivocal despite limiting instructions. The judgment was reversed and the case was remanded for a new trial. Mullins, C. J., dissenting, joined by Dannehy, J., would have found any evidentiary error harmless because the state's identification evidence was strong and the prior misconduct played only a minor role.