People v. Dorm, 12 N.Y.3d 16 (2009)
Evidence of a defendant’s prior bad acts is inadmissible to show propensity for crime but may be admissible to prove identity if identity is genuinely in issue and the prior acts are sufficiently unique and probative.
Summary
The New York Court of Appeals addressed the admissibility of prior bad acts to establish identity. The defendant was convicted of assaulting his wife. At trial, the prosecution introduced testimony from the defendant’s ex-wife regarding similar abusive behavior. The Court of Appeals reversed the Appellate Division’s order, holding that the ex-wife’s testimony was admissible to prove the defendant’s identity because the specific method of abuse was sufficiently unique and because the defendant’s plea of not guilty placed identity in issue. This case emphasizes the narrow exception to the general rule against using prior bad acts to show propensity, focusing instead on their probative value for establishing identity when genuinely disputed.
Facts
The defendant, Dorm, was accused of assaulting his wife. The prosecution presented evidence that Dorm had previously assaulted his ex-wife in a similar manner, including tying her up and inflicting burns. The victim testified that Dorm had assaulted her over a 12-hour period. The defense argued that the ex-wife’s testimony was inadmissible because it served only to demonstrate Dorm’s propensity for violence.
Procedural History
The trial court admitted the ex-wife’s testimony. Dorm was convicted. The Appellate Division reversed the conviction, finding that the ex-wife’s testimony was improperly admitted to show Dorm’s propensity for violence. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in admitting the testimony of the defendant’s ex-wife regarding prior similar bad acts to establish the defendant’s identity as the perpetrator of the charged crime.
Holding
Yes, because the identity was not conclusively established by other evidence, and the method of abuse used was sufficiently unique to be probative of identity. Admission of the evidence was not solely to show propensity.
Court’s Reasoning
The Court of Appeals reasoned that while evidence of prior bad acts is generally inadmissible to show a defendant’s propensity for crime, it can be admissible to prove identity under the Molineux exception if identity is genuinely in issue and the prior acts are sufficiently unique and probative. The Court emphasized that a simple plea of not guilty places identity in issue unless identity is conclusively established through other evidence. The Court found that the specific manner of abuse described by the ex-wife was sufficiently unique to be probative of identity. The Court noted that the trial court was aware of the defendant’s potential defense strategy based on prior testimony at a probation violation hearing, making the admission of the evidence appropriate at the time. The dissent argued that identity was not truly in issue because the complainant identified her husband as her attacker, and that the evidence was introduced to show propensity, violating People v. Molineux. The dissent emphasized that the People’s summation focused on the defendant’s propensity to abuse women. However, the majority held that because the defendant maintained his innocence, identity was not conclusively established, and the ex-wife’s testimony was properly admitted to prove that the defendant was the perpetrator of the crime.