People v. Lobdell

Defendant was convicted of criminal sexual assault. Court properly admitted evidence of Defendant's conviction of rape 30 years prior, given factual similarities including uninvited entrance into the victims' home, the use of force, nonconsensual sex, and adult women victims. Factual differences do not outweigh general areas of similarity necessary for admission. Court erred in failing to conduct preliminary inquiry as Defendant made clear claim of ineffective assistance of counsel, in written letter to court and verbally, even though Defendant did not use the phrase "ineffective assistance of counsel".(LYTTON, concurring; McDADE, dissenting.)