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Evidence of any facts relevant to a material fact in issue except where the sole relevancy is character or propensity of the accused is admissible unless precluded by some specific exception or rule of exclusion. This rule applies to relevant similar fact evidence even though it points to the commission of another crime. The matter of relevancy should be carefully and cautiously considered by the trial judge. However, when found relevant within the limits of the stated rule, such evidence should be permitted to go to the jury.
Defendant Ralph Williams was convicted of rape. In challenging his conviction, defendant contended that the trial court committed error when it allowed into evidence testimony regarding his involvement in a similar factual situation that had occurred six weeks before the matter at issue.
Did the trial court err in allowing a similar factual evidence which tended to establish a collateral crime?
The court stated that the testimony of the earlier event had a tendency to have revealed the commission of a collateral criminal act that involved another person and it was unrelated by parties, facts, time, or circumstances to the crime laid in the indictment. The court stated that the evidence regarding the earlier incident was clearly admissible because it was relevant to several of the issues involved. The court also stated that the evidence of the earlier incident had probative value to have established a plan, scheme, or design. The court also noted that the earlier evidence was also relevant to have met the anticipated defense of consent. The court held that it was not error for the trial court to have allowed the testimony of the earlier event to have been admitted. Defendant's sentence and conviction were affirmed.