People v. Robinson, 68 N.Y.2d 536 (1986)
For evidence of a prior crime to be admissible to prove identity, the prosecution must establish the defendant’s identity as the perpetrator of the prior crime by clear and convincing evidence.
Summary
Robinson was convicted of attempted robbery. The prosecution introduced evidence of a prior bank robbery to establish identity. The New York Court of Appeals reversed, holding that the evidence connecting Robinson to the prior robbery was insufficient. The Court clarified that while prior crime evidence can be admissible to prove identity, it requires clear and convincing proof that the defendant committed the prior crime. The Court reasoned that admitting evidence based on a lower standard risks prejudice and jury confusion, outweighing the probative value. This case emphasizes the high standard required for admitting prior crime evidence to prove identity.
Facts
On December 12, 1978, an individual attempted to rob a Home Savings Bank teller, Lettie Pinney, in Albany. The robber handed Pinney a note demanding money, but fled when she passed the note to another teller. Pinney and another customer gave descriptions of the suspect. Prior to this incident on December 5, 1978, the Central Savings and Loan Association, also in Albany, was successfully robbed. Vickie Owens, a teller, received a similar note and handed over money. Neither teller could identify Robinson as the perpetrator. The prosecution sought to introduce evidence of the Central Savings robbery to prove Robinson’s identity and intent in the Home Savings attempted robbery.
Procedural History
Robinson was convicted of attempted robbery in the third degree. The Appellate Division affirmed the conviction. Robinson appealed to the New York Court of Appeals, arguing that the evidence of the prior robbery was improperly admitted. The Court of Appeals granted leave to appeal.
Issue(s)
Whether evidence of a prior uncharged crime is admissible to prove the identity of the defendant as the perpetrator of the charged crime when the evidence linking the defendant to the prior crime is less than clear and convincing.
Holding
No, because a trial court abuses its discretion when it admits evidence of an uncharged crime to prove identity based on less than clear and convincing proof that the defendant committed both the prior crime and that the prior crime had a unique modus operandi.
Court’s Reasoning
The Court reasoned that the Molineux rule excludes evidence of uncharged crimes unless its probative value outweighs the risk of prejudice. When identity is at issue, evidence of a prior crime is admissible only if the modus operandi is unique and there is clear and convincing evidence that the defendant committed the prior crime. The Court stated, “To make evidence of a prior uncharged crime relevant, there must be more than a unique method involved, for, as Molineux long ago stated, ‘the naked similarity of *** crimes proves nothing’ (168 NY, at p 316).” The Court emphasized that the probative value depends on showing the method is unique and that the defendant committed the prior crime. Prejudice is a significant concern, especially with heinous crimes. The Court determined that the evidence linking Robinson to the Central Savings robbery was insufficient. No fingerprints were found, and no one identified him. The only link was handwriting analysis, which was contested. The Court concluded that the evidence of the Central Savings robbery was erroneously admitted, requiring reversal and a new trial. The Court emphasized that the trial court abused its discretion as a matter of law, in admitting evidence of an uncharged crime on the issue of identity on less than clear and convincing proof of both a unique modus operandi and of defendant’s identity as the perpetrator of the crime.