State v. Cofield

The opinion of the Court was delivered by

O’HERN, J.

This appeal concerns the admissibility of other-crime evidence under Evidence Rule 55 to prove a fact in issue other than the propensity of a defendant to commit crime. We hold that the trial court did not abuse its discretion in ruling evidence of a subsequent illegal drug incident to be relevant and admissible for establishing defendant’s constructive possession of illegal drugs during an earlier incident that is the subject of this prosecution. We find sufficient similarity between the two incidents involving the same location to…