“Motive” as a Reason to Admit Otherwise Inadmissible Evidence at Trial

When can an Arizona court admit evidence regarding a previous, seemingly unrelated offense during criminal proceedings? The answer is tricky, as there are multiple exceptions to the rule of evidence indicating that testimony about a prior bad act is inadmissible during trial. One such exception is when the evidence speaks to a party’s motive, opportunity, intent, preparation, or plan. In a recent case before the Arizona Court of Appeals, Division Two, the defendant successfully appealed his conviction by arguing that certain evidence at trial should have been admitted under this “motive” exception.

Trial Proceedings

In the case before the Arizona court, the defendant was originally charged with aggravated assault and domestic violence assault. The State charged him after his girlfriend, the victim in the case, called police officers indicating that the defendant had physically assaulted her. During the defendant’s trial, he tried to present evidence demonstrating that the victim had previously made multiple false allegations against him in an attempt to get the defendant into custody. The trial court told him he could not present this evidence, given that it was extrinsic and not relevant to the offense at issue. A jury later found the defendant guilty as charged.

Appeal

On appeal, the defendant argued the evidence should have been admitted, since it spoke to the victim’s motive in the case. The higher court agreed. Certain evidence of other crimes, said the court, may be admitted to show a person’s motive. Here, the victim’s prior fabrications could have established her intent to lie about the assault in the present case. This evidence could have made a difference in the outcome of the defendant’s case, as the jury would have been more likely to find him not guilty had it heard the evidence that was excluded.

The court vacated the defendant’s conviction and remanded the case back down to the trial court for further proceedings. The case serves as a powerful reminder that familiarity with Arizona rules of evidence can make or break the outcome of a trial. To give yourself the best possible chance of success, hire an experienced and aggressive Phoenix violent crimes attorney, one that can litigate your case with full knowledge of the evidence rules as well as the exceptions that a court might apply.

Are You on the Lookout for a Phoenix Violent Crimes Attorney to Fight Your Charges?

At the Law Office of James E. Novak, we make your priorities our priorities, and we make your acquittal our number one goal. If you are facing criminal charges in Arizona, there is no better choice for your representation. We have years of experience representing the accused, and our familiarity with the court system, rules of evidence, and various litigation strategies make us well poised to take on your case. For a free and confidential consultation with a qualified, experienced Phoenix violent crimes attorney, give our office a call today at 480-413-1499. You can also fill out our online form to have a member of our team get back in touch with you as soon as possible regarding your next steps.