Pratt v. State

Defendant was on trial for aggravated battery in the beating of his stepdaughter and pregnant wife. The State sought to present evidence that during the 18 months preceding the beatings, defendant had beaten his wife on 3 different occasions — the most recent barely a few months before the alleged crimes. The judge allowed this Williams rule 1 evidence over the objection of defendant. We reverse.

These are the events. One morning the daughter heard defendant say something to the effect that he was unhappy with the mother and stepdaughter. Hearing footsteps behind her, the daughter turned…