People v. Currie

Defendant was charged with multiple counts of domestic battery. The State filed a motion in limine pursuant to section 115-7.4 of the Code of Criminal Procedure seeking admission of certified copies of conviction for defendant’s prior domestic battery offenses. The trial court denied the motion concluding that, without additional evidence, such as live testimony, the admission of the certified convictions would be more prejudicial than probative. The appellate court reversed and remanded, agreeing with the State’s argument on appeal that certified copies of conviction alone are an acceptable method of introducing propensity evidence. (CAVANAGH and HARRIS, concurring.)