☢ test - Í

limited the jury’s consideration of the evidence of prior difficulties to motive, intent, and bent of mind, the trial court did not err when it did not further constrict the jury’s consideration of the evidence to only motive and intent.” Jones v. State, 283 Ga.App. 812, 642 S.E.2d 887 (March 1, 2007). In his prosecution for assaults against his mother and brother, “[t]he evidence regarding Jones’ numerous convictions and thefts from his mother and brother were admissible as prior difficulties between the victims and the defendant. See Wall v. State, 269 Ga. 506, 509(2) (500 S.E.2d 904) (1998).” Milner v. State, 281 Ga. 612, 641 S.E.2d 517 (January 22, 2007). At defendant’s murder trial, witness testified that defendant had previously pointed a gun at an associate of the man he later helped kill. “[This] testimony amounted to evidence of prior difficulties between [defendant] and [murder victim] Griffin.” Mahan v. State, 282 Ga.App. 201, 638 S.E.2d 366 (November 1, 2006). In defendant’s prosecution for aggravated assault against his girlfriend’s infant son, trial court properly admitted evidence of “prior difficulties” wherein defendant left child alone when he was supposed to be babysitting, and another wherein he cut up the child’s shoes after arguing with girlfriend. “The two incidents at issue were admissible to show Mahan’s motive, intent, and bent of mind in shaking Trevioun. [Cit.]” Clements v. State, 279 Ga.App. 773, 632 S.E.2d 702 (June 13, 2006). Prior sexual offenses committed against the same minor victims were admissible as prior difficulties. Glidewell v. State, 279 Ga.App. 114, 630 S.E.2d 621 (April 27, 2006). Full court opinion. Overruled on other grounds, Reynolds v. State , 285 Ga. 70, 673 S.E.2d 854 (February 23, 2009). 1. “Glidewell complains that his trial counsel allowed [victim’s boyfriend] Kempf to testify, without objection, that Glidewell broke into Kempf’s house in Hawaii to get a camera belonging to the victim, and that Glidewell and Kempf had a confrontation in which they ‘struggled’ and ‘wrestled.’ Trial counsel also did not object when the prosecutor asked the victim’s daughter if she was protected by the restraining order against Glidewell. Evidence showed that Kempf was living with the victim when Glidewell allegedly broke into Kempf’’s home in order to retrieve the victim’s camera, and that the victim was present when the two men wrestled. Therefore, Kempf’s testimony directly involved the victim and was relevant to shed light on the relationship between Glidewell and the victim and the possible motives for the crime. It follows that Kempf’s testimony was admissible as evidence of a prior difficulty between Glidewell and the victim.” 2. Victim’s boyfriend testified that “ I had always thought that [Glidewell] was capable ... of harming [the victim].” Held, this was not objectionable as a comment on future dangerousness; [i]n context of [boyfriend] Kempf’s testimony, Kempf was simply explaining his motives for going to Glidewell’s Hawaii residence.” Davenport v. State, 278 Ga.App. 16, 628 S.E.2d 120 (February 22, 2006). Defendant’s prior acts of molestation against same child were properly admissible as prior difficulties. “Davenport claims that his trial counsel was ineffective because he did not object when the State introduced documentary evidence and elicited testimony concerning his indictment, arrest, guilty plea, incarceration, terms of probation, and probation violations associated with the prior charges of child molestation [against the same victim]. He claims that this evidence and testimony improperly introduced his character into the proceedings and was highly prejudicial. Davenport’s claim lacks merit. ‘[E]vidence of the defendant’s prior acts toward the victim[,] be it a prior assault, a quarrel, or a threat[,] is admissible when the defendant is accused of a criminal act against the victim.’ (Punctuation and footnote omitted .) Cunningham v. State, 243 Ga.App. 770, 771(1) (533 S.E.2d 735) (2000). So long as a proper limiting instruction is given (as it was in this case on several occasions), evidence of such ‘prior difficulties’ between the defendant and victim ‘may be considered more broadly than evidence of a similar transaction’ and ‘is admissible to show the defendant’s intent, bent of mind, and course of conduct. Such evidence may be admitted to show a continuing pattern of conduct in committing [a criminal offense] upon the victim.’ (Citation, punctuation, and emphasis omitted.) Hall v. State, 255 Ga.App. 631, 635(4)(a) (566 S.E.2d 374) (2002).” “[A]ny reference to the additional fact that Davenport had been arrested and spent time in jail for the prior offense at most only incidentally placed his character at issue. The jury surely would have assumed that Davenport had been arrested and spent time in jail on the two counts of child molestation to which he pled guilty, even if they had not been explicitly told so. Thus, testimony that Davenport had been in jail was not unduly prejudicial or otherwise improper since it ‘did not tell the jury anything it did not already know about [Davenport].’ Roberts v. State, 212 Ga.App. 607, 608(2) (443 S.E.2d 4) (1994). See also Waldrip v. State, 267 Ga. 739, 748(11) (482 S.E.2d 299) (1997).” Brown v. State, 278 Ga. 810, 607 S.E.2d 579 (January 10, 2005). Murder and related convictions affirmed. Prior difficulties may be proven by introducing certified copies of criminal accusation and guilty plea. Accord, McNear v. State ,