Illinois Appellate Court
Criminal Court
Evidence
Defendant was convicted of burglary, after having stolen a decoy purse from front passenger seat through an open window of an unmarked police car. Court properly applied balancing test in admitting evidence of Defendant's prior theft convictions. Prosecutor's statement in closing argument, that the jury knew that Defendant was a thief because of his two prior convictions in 1998 and 1999 for misdemeanor retail theft, was improper as it suggesed propensity, but remark was made in isolation and was not unduly prejudicial, and court gave admonishments as to limiting instructions. (FITZGERALD SMITH and J. GORDON, concurring.)