168 N.Y. 264 (1901)
Evidence of other crimes is inadmissible if its primary purpose is to demonstrate a defendant’s propensity to commit crimes, but it may be admissible to prove a specific element of the crime charged, such as identity, motive, intent, absence of mistake, or a common scheme or plan, provided its probative value outweighs the potential for prejudice.
Summary
Molineux was convicted of murder by poisoning. The prosecution introduced evidence that Molineux had previously poisoned another individual, Adams, to prove his identity as the murderer of Mrs. Young. The New York Court of Appeals reversed the conviction, holding that the evidence of the prior poisoning was inadmissible because it primarily served to show Molineux’s criminal propensity, and the circumstances surrounding the two poisonings were not sufficiently unique to establish identity. The Court articulated the general rule that evidence of other crimes is inadmissible to prove the crime charged unless it falls within a recognized exception.
Facts
Mrs. Young died after consuming bromo seltzer laced with cyanide. Suspicion fell on Molineux. The prosecution presented evidence that Molineux had a motive to harm Mrs. Young’s friend, Harry Cornish. The prosecution also introduced evidence that a package containing cyanide had been sent to Cornish. Over objection, the prosecution presented evidence that Molineux had previously poisoned a man named Adams with cyanide.
Procedural History
Molineux was convicted of first-degree murder in the trial court. He appealed to the New York Court of Appeals. The Court of Appeals reversed the conviction and ordered a new trial because of the improper admission of evidence of the prior poisoning of Adams.
Issue(s)
Whether evidence of a prior, uncharged crime (the poisoning of Adams) is admissible to prove the defendant’s identity as the perpetrator of the charged crime (the poisoning of Mrs. Young).
Holding
No, because the evidence of the prior poisoning primarily served to show the defendant’s criminal propensity, and the circumstances of the two poisonings were not sufficiently unique to establish the defendant’s identity. The Court held that “It is a principle of the common law that evidence of other crimes is inadmissible to prove the crime charged.”
Court’s Reasoning
The Court of Appeals acknowledged that evidence of other crimes is sometimes admissible to prove a specific element of the crime charged, such as motive, intent, absence of mistake, a common scheme or plan, or identity. However, the Court emphasized that the exceptions to the general rule of inadmissibility must be carefully applied. The Court stated that “The exceptions to the rule cannot be stated with categorical precision.” The Court found that the evidence of the prior poisoning of Adams did not fall within the identity exception because the circumstances of the two poisonings were not sufficiently unique. The Court reasoned that the primary purpose of the evidence was to show that Molineux had a propensity to commit poisoning, which is an improper basis for a conviction. The court further noted, “The very fact that it is much easier to believe in the guilt of an accused person when it is known or suspected that he has previously committed a similar crime proves the dangerous tendency of such evidence to convict, not upon the evidence of the crime charged, but upon the super-added evidence of the previous crime.” Evidence is inadmissible where “the only connection between the two crimes is a similar modus operandi.”