People v. Ingram, 71 N.Y.2d 474 (1988)

Evidence of a subsequent, similar crime is admissible to prove a defendant’s intent or state of mind when the defendant places their intent at issue by claiming they acted innocently or without knowledge of the crime.

Summary

Ingram was convicted of robbery for acting as a getaway driver. At trial, he claimed he was unaware of his passenger’s intent to rob the gas station. The prosecution introduced evidence of a subsequent, similar robbery Ingram committed with the same passenger 18 days later. The New York Court of Appeals held that evidence of the subsequent crime was admissible under the intent exception to the Molineux rule because Ingram’s testimony put his intent directly at issue. The court reasoned that the repetition of similar acts makes an innocent explanation less probable, regardless of whether the similar act occurred before or after the charged crime.

Facts

On December 21, 1984, Ingram drove a red van to a gas station in Manhattan. His passenger, Ronnell Harrison, robbed the attendant after Ingram requested gas. Ingram claimed he was unaware of Harrison’s intent. Eighteen days later, on January 8, 1985, Ingram, driving the same van, acted as the getaway driver for Harrison during a similar robbery at a gas station in Queens. Ingram was arrested but denied any knowledge of or participation in the Queens robbery.

Procedural History

Ingram was convicted of robbery in the second degree in Manhattan. The Appellate Division affirmed the conviction. Ingram appealed to the New York Court of Appeals, arguing that the trial court erred in admitting evidence of the subsequent Queens robbery. The Court of Appeals affirmed the conviction.

Issue(s)

Whether evidence of a subsequent crime is admissible to prove a defendant’s intent or state of mind when the defendant claims they acted innocently and without knowledge of the initial crime.

Holding

Yes, because the repetition of the same inculpatory conduct makes the claim of innocent intent less probable, regardless of whether the similar conduct occurred before or after the crime in question.

Court’s Reasoning

The Court of Appeals relied on the intent exception to the Molineux rule, which allows the admission of evidence of uncharged crimes when a defendant’s intent is at issue. The court reasoned that by claiming he was unaware of Harrison’s intent to rob the gas station, Ingram put his intent directly in question. “[I]t is the repetition * * * that is significant, and a subsequent instance reduces the probability of innocence equally as well as a prior one.” 2 Wigmore, Evidence § 321, at 285 (Chadbourn rev 1979). The court found that the similarity between the two robberies (same defendant, same accomplice, same vehicle, similar crime) made it less likely that Ingram was an unwitting participant in either. The court also noted precedent allowing subsequent acts to show predisposition and fraudulent intent. The court distinguished between using subsequent acts to prove actual knowledge of a specific fact (which is not permissible) and using them to show the improbability of a defendant’s claim of unwitting complicity. The court emphasized that the trial court provided limiting instructions, and no challenge to those instructions was properly preserved for appeal. Therefore, the Court of Appeals only considered whether the evidence was properly admitted to demonstrate intent. The Court concluded: “His presence with Harrison at the second robbery clearly tended to discredit his testimony that his stop to buy gas at the earlier robbery site was merely coincidental and without criminal purpose and that, while he did, in fact, aid Harrison, he did so unintentionally because he was unaware that Harrison was committing the robbery.”