People v. Gist

Court was within its discretion in denying State's motion in limine to admit evidence of prior domestic batteries allegedly committed by Defendant against his son. Court reasonably concluded that testimony was more prejudicial than probative. Witness did not actually see Defendant strike victim, could not say whether he struck with closed fist or open hand, and single incident was of limited probative value in establishing propensity. Risk that jury might speculate on clear pattern of violence against victim was prejudicial. (BURKE and JORGENSEN, concurring.)