People v. Jenk

Defendant was convicted, after bench trial, of misdemeanor domestic battery. Court properly admitted other-crimes evidence as relevant for purposes of demonstrating Defendant's motive, intent, or absence of mistake in harming victim (his girlfriend). The fact that court did not base its ruling on another permissible basis, the continuing narrative doctrine, did not necessarily mean that court's ruling was erroneous. Evidence was sufficient to sustain conviction. Victim testified about incident that gave rise to charged offense, and about 3 prior incidents of domestic violence and supporting photographic evidence. (CONNORS and HARRIS, concurring.)