State v. Juan J.
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The Supreme Court reversed the judgment of the trial court convicting Defendant of sexual assault in the first degree, attempt to commit sexual assault in the first degree, and risk of injury to a child, holding that the trial court abused its discretion in admitting irrelevant, uncharged misconduct evidence.
At issue on appeal was whether the trial court abused its discretion in admitting uncharged misconduct evidence of alleged prior incidents of sexual abuse of Defendant against the complainant. The Supreme Court answered in the positive, holding (1) in a general intent crime case where the theory of defense is that the alleged conduct did not occur, rather than a theory of defense in which the conduct occurred unintentionally, uncharged misconduct is irrelevant and inadmissible to prove intent; and (2) the uncharged misconduct evidence in this case was irrelevant to the issue of intent and was therefore inadmissible.
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