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When a man is put upon trial for one offense he is to be convicted, if at all, by evidence which shows that he is guilty of that offense alone, and that, under ordinary circumstances, proof of his guilt of one or a score of other offenses in his lifetime is wholly excluded. The general rule is against receiving evidence of another offense. A person cannot be convicted of one offense upon proof that he committed another, however persuasive in a moral point of view such evidence may be. It would be easier to believe a person guilty of one crime if it was known that he had committed another of a similar character, or, indeed, of any character; but the injustice of such a rule in courts of justice is apparent. It would lead to convictions, upon the particular charge made, by proof of other acts in no way connected with it, and to uniting evidence of several offenses to produce conviction for a single one.
Roland B. Molineux was accused of the murder of a victim who had ingested cyanide of mercury that Molineux had allegedly mailed to another person. Evidence regarding a previous crime allegedly committed by Molineux was admitted at trial, and the Court of General Sessions of the Peace in and for the City and County of New York convicted defendant. Defendant appealed. The State claimed that there was a connection between the two crimes so as to justify proof of the former in support of the latter. Defendant disputed the claim and urged that the trial court erred in permitting comparison of the handwriting on the poison package mailed to the intended victim with exemplars supplied by Molineux.
Was evidence admissible about the killing of one of Molineux’ alleged prior victims?
The court held that none of the evidence tending to prove the poisoning of the first victim was relevant or competent to prove the murder of the victim in the instant case. That the two crimes were parallel in means employed did not identify Molineux as the murderer of the second victim. There was no legal connection between the two cases. The trial court did not err in receiving into evidence handwriting exemplars for comparison with a handwritten address on the package delivered to defendant's intended victim. Molineux had the legal right to refuse to write the exemplars, defendant instead acceded to the request, and there was no ground upon which the writings produced could be excluded.