Illinois Appellate Court
Criminal Court
Evidence
Defendant was convicted, after jury trial, of felony domestic battery. Court properly allowed evidence of Defendant's prior incident of domestic battery, to same victim, to be admitted at trial per Section 115-20 of Code of Criminal Procedure. Section 115-20 is intended to allow for admission of evidence regarding the prior incident itself, rather than only the fact of the prior conviction. Court may properly admit evidence of prior qualifying incident of domestic battery of which Defendant was convicted and which involved same victim. Section 115-7.3 of Code allows for admission of propensity evidence in domestic battery cases after court performs similar type weighing analysis. (LYTTON and SCHMIDT, concurring.)