State v. Teitsworth

Evidence of uncharged misconduct that is introduced to show hostile motive toward the victim and is also probative of intent must pertain to a disputed issue and meet the Johns test.

Defendant appealed a conviction of fourth-degree assault. Defendant was in an altercation with his then-girlfriend that resulted in her sustaining injuries. Defendant claimed he acted in self-defense. The State introduced evidence of prior uncharged altercations between Defendant and the victim to show intent and to disprove the self-defense claim. The trial court allowed admission of this evidence. Defendant appealed, arguing that the evidence was improper as propensity evidence and irrelevant to the facts of this case. As an initial matter, the Court held that prior uncharged altercations are only admitted when they are used to prove disputed issues that go beyond propensity or bad character. Because Defendant did not dispute intent, the trial court improperly admitted the evidence on that basis. However, Defendant’s claim of self-defense creates a disputed issue beyond propensity or bad character by which the prior altercations may be admitted. Finally, the Court analyzed the prior altercations using the six criteria of the Johns test to determine if the evidence was properly admitted. The prior uncharged altercations met the test and the trial court was correct in admitting the uncharged misconduct. Affirmed.