State v. Villazana

Summary

The court held that admitting testimonial evidence of prior domestic violence violated the third step of the Rule 404(b) analysis because the charged crimes had not yet been independently established, but the error was harmless after later testimony supplied sufficient evidence of the charged conduct. Villazana waived any challenge to the admitted text messages and failed to preserve a Rule 403 objection. The court also held the verdict was not legally inconsistent because the terrorizing conviction could be rationally reconciled with the instructions and substantial evidence.