People v. Smart

Summary

The Illinois Supreme Court held that a defendant charged with a specific-intent offense places intent at issue even if he denies the conduct and does not contest intent. Nevertheless, the trial court improperly admitted evidence of Smart's prior misconduct because its relevance depended on an impermissible propensity inference and the evidence did not satisfy the statutory exceptions for propensity evidence. The court found the error harmless in the bench trial, reversed the appellate court's judgment, and remanded for consideration of unresolved arguments.