Garland v. State

SHEPARD, Chief Justice.

Indiana Evidence Rule 404(b) is customarily used by criminal defendants to seek exclusion of evidence about their own prior bad acts. Appellant Sharon Garland presents a question of first impression: does Rule 404(b) apply to evidence about persons other than the defendant? We conclude that it does.

Facts and Procedural History

On the evening of January 24, 1996, David Garland was shot four or five times in the head. The events leading up to his murder, however, began more than two years earlier.

In October 1994, the Knox City Court ordered Sharon and David's son Allen to…