People v. Clark

Defendant was convicted of theft for stealing a bicycle. At trial, court improperly allowed evidence that four years prior Defendant had stolen another bicycle in same area, as it did not prove intent to commit theft or his identity in a permissible way, but relied on inference that he possessed propensity to commit theft. However, error was harmless as evidence was overwhelming against Defendant. Court erred in delivering incomplete version of IPI Criminal 3.14, but not plain error, as jury was told that it "may" consider evidence of prior conviction, and other instructions told jury it could give whatever weight it deemed appropriate. (FITZGERALD SMITH and COBBS, concurring.)