People v. Watkins

Defendant was convicted, after jury trial, of unlawful possession of controlled substance with intent to deliver and sentenced to 8 years. Court erred in admitting photos of drug-related text-message conversations with the name "Charles" found on a cell phone in close proximity to drugs as evidence that Defendant had connection to cell phone and, circumstantially, to the drugs. Court did not abuse its discretion in admitting evidence of Defendant's prior conviction for possession of cannabis with intent to deliver as some evidence of Defendant's intent to deliver cocaine in this case. Requirement of general threshold similarity between facts of prior crime and current offense was satisfied. (HOLDRIDGE, concurring; WRIGHT, specially concurring.)