23 N.Y.3d 239 (2014)
Evidence of a defendant’s prior bad acts is admissible to rebut an extreme emotional disturbance defense if it demonstrates a pattern of behavior that contradicts the defense’s claims about the defendant’s state of mind at the time of the crime.
Summary
In People v. Green, the New York Court of Appeals addressed the admissibility of evidence regarding a defendant’s prior uncharged bad acts when the defendant raised an extreme emotional disturbance defense. The court held that evidence of a prior act of violence, occurring before a traumatic event that the defendant claimed caused PTSD, was properly admitted to rebut the defense’s assertion that the defendant was not prone to violence prior to the incident. However, the court found that evidence of an act occurring after the charged crime was inadmissible. The court affirmed the conviction, finding the error in admitting the later act to be harmless.
Facts
The defendant shot multiple people, killing one and injuring others, after witnessing his friend in a street altercation. The defendant did not deny shooting the victims but argued that he was acting under extreme emotional disturbance (EED) caused by post-traumatic stress disorder (PTSD) stemming from a prior stabbing. The defense presented witnesses who testified to the defendant’s non-violent nature before the stabbing. To rebut the EED defense, the prosecution cross-examined the defense witnesses and introduced evidence of violent incidents before and after the stabbing, including a 2002 assault, a 2005 assault, and a 2010 incident in prison. The trial court admitted evidence of all three incidents, but ultimately the Court of Appeals found that the third was improperly admitted. The jury rejected the EED defense and convicted the defendant of second-degree murder and attempted murder.
Procedural History
The trial court admitted the evidence of prior bad acts. The jury convicted the defendant. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal, specifically addressing the admissibility of evidence concerning the defendant’s prior actions to rebut the EED defense.
Issue(s)
1. Whether the trial court properly admitted evidence of the 2002 and 2005 incidents to rebut the defendant’s extreme emotional disturbance defense.
2. Whether the trial court properly admitted evidence of the 2010 incident to rebut the defendant’s extreme emotional disturbance defense.
Holding
1. Yes, because the 2002 incident was relevant to the defendant’s reaction patterns prior to his claimed trauma, and directly rebutted the defendant’s claims.
2. No, because the 2010 incident was not relevant to the defendant’s state of mind at the time of the shooting.
Court’s Reasoning
The court reiterated the general rule that evidence of uncharged crimes or prior misconduct is inadmissible if its only purpose is to show a defendant’s propensity to commit the crime charged. However, the court recognized an exception when the defendant