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People v. Williams.

2020 CO 78. No. 16SC391. Criminal Law—Evidence—Uncharged Misconduct—Relevance.

November 9, 2020

The People petitioned for review of the Court of Appeals’ judgment reversing Williams’s conviction for distributing a schedule II controlled substance. At trial, the district court admitted evidence pursuant to CRE 404(b) of a prior incident in which Williams pleaded guilty to selling cocaine. The Court of Appeals found that the district court abused its discretion in admitting this evidence for the limited purposes of demonstrating “modus operandi and common plan, scheme, or design,” largely on the grounds that the evidence in question did not meet the strictures imposed by prior case law for admitting uncharged misconduct evidence pursuant to CRE 404(b) for these particular purposes, and because the error was not harmless.

The Supreme Court affirmed, although for different reasons. The Court held that because the incremental probative value of this evidence relative to any material issue in the case was substantially outweighed by the danger that it would be unfairly prejudicial, the district court abused its discretion in admitting it.


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