State v. Atkins.

Summary

The court vacated the trial court’s order excluding evidence concerning a prior murder and remanded for reconsideration under the proper framework for other-acts evidence. It held that the trial court improperly relied on collateral-estoppel principles, failed to tie relevance and balancing to the purposes actually advanced by the State, and excluded otherwise admissible evidence merely “out of an abundance of caution.” The court also held that the doctrine of chances is not an independent admissibility purpose, although it may explain the relevance of evidence offered to prove intent, knowledge, identity, or absence of mistake.