People v. Porter-Boens

Defendant was convicted, after bench trial, of aggravated battery and resisting a police officer. Court correctly quashed Defendant's subpoena for records of civilian complaints against arresting officer, who had 19 prior complaints filed against him. Court properly found that 3 complaints were too remote in time to be relevant, and the remaining concerned generalized misconduct. In determining whether prior allegations of misconduct is admissible, question of relevancy is a determination to be made by trial court after considering temporal proximity of past misconduct, whether there is a repetition of similar misconduct, and similarity of past conduct to conduct at issue. (PALMER and TAYLOR, concurring.)