State v. Sanders

Defendant appeals his jury conviction of aggravated domestic assault, 13 V.S.A. § 1043(a)(2), claiming that the court erred by (1) permitting the State to introduce “prior bad acts” evidence without giving defendant proper notice, (2) admitting evidence that defendant had assaulted the victim on prior occasions, and (3) allowing the State to question the victim about prior assaults after she recanted that they had occurred. We affirm.

The assault charge stemmed from a confrontation on March 31, 1996, in Burlington. The victim, defendant’s live-in girlfriend, came home that evening with a…