☢ test - Í

prior difficulty, this testimony may be considered more broadly than evidence of a similar transaction. Prior difficulties are relevant in construing the defendant's current state of mind or conduct in light of his previous actions toward the same victim. ‘Evidence of previous difficulties between a defendant and a victim is admissible to show the defendant's intent, bent of mind, and course of conduct. ’ (Citations omitted; emphasis supplied.) Kettman v. State, 257 Ga. 603, 606(7), 362 S.E.2d 342 (1987). Such evidence may be admitted to show a continuing pattern of conduct in committing battery upon the victim. Sutton v. State, 236 Ga.App. 363, 364–365, 511 S.E.2d 888 (1999). The earlier incident between Hill and his infant son was virtually identical to the events that took place shortly before the child's death. The fact that Hill, on a previous occasion, responded to his son's continual crying by physically attacking him and acknowledging that he might kill the child was highly probative of Hill's state of mind and course of conduct on the later occasion.” Accord, Cunningham v. State, 243 Ga.App. 770, 533 S.E.2d 735 (April 11, 2000) (“The prior difficulties in this case unquestionably showed a pattern of simple batteries by Cunningham against the victim which culminated in the commission of aggravated assault and rape.”). Porter v. State , 243 Ga.App. 498, 532 S.E.2d 407 (March 24, 2000). Convictions for child cruelty and contributing to deprivation of a minor reversed on other grounds, but no error in allowing victim’s father to testify “that after prior visits to Porter, the child had returned home bearing various minor injuries.” Crawley v. State, 240 Ga.App. 891, 525 S.E.2d 739 (November 18, 1999). Defendant’s convictions for burglary, armed robbery and aggravated assault affirmed; trial court properly admitted “prior difficulty” evidence: “The prior difficulty evidence presented by the State consisted of [victim] Smith's testimony that, within the week before the incident giving rise to the charges here, Crawley had broken down the door of Smith's father's room at Dial Inn looking for Smith and the $3,000 which Crawley claimed Smith owed to him. Smith's testimony regarding the prior event was admissible because it helped explain the motive for these crimes and Crawley's course of conduct. Wall v. State, 269 Ga. 506, 508(2), 500 S.E.2d 904 (1998).” Crimes on trial involved armed invasion of Smith’s apartment. Buice v. State, 239 Ga.App. 52, 520 S.E.2d 258 (June 29, 1999), affirmed on other grounds, 272 Ga. 323, 528 S.E.2d 788 (May 1, 2000). “Buice complains that the trial court erred in allowing the victim to testify about other instances of molestation by Buice that were not listed in the indictment. However, there is no requirement that the State comply with USCR 31.3 when presenting evidence of prior difficulties between the victim and the accused. Wall v. State, 269 Ga. 506, 509(2), 500 S.E.2d 904 (1998).” Accord, Mallory v. State , 271 Ga. 150, 517 S.E.2d 782 (June 1, 1999); Bean v. State , 239 Ga.App. 106, 521 S.E.2d 19 (June 30, 1999); Camphor (May 1, 2000), above; Cooks v. State , 289 Ga.App. 179, 656 S.E.2d 851 (January 14, 2008). Rodriguez v. State, 271 Ga. 40, 518 S.E.2d 131 (May 3, 1999). Trial court properly admitted evidence of temporary restraining order issued against defendant five days before he shot and killed girlfriend. “[T]he evidence was relevant to prove a material issue in dispute – whether Rodriguez acted under a delusional compulsion and was unable to distinguish between right and wrong when he shot the victims, or whether he deliberately sought out and killed Posada because of prior difficulties between them. ‘[T]he prior acts are evidence of the relationship between the victim and the defendant and may show the defendant's motive, intent, and bent of mind in committing the act against the victim.’ Wall v. State, 269 Ga. 506, 509(2), 500 S.E.2d 904 (1998).” Parrish v. State, 237 Ga.App. 274, 514 S.E.2d 458 (March 11, 1999). “‘[T]he true test of admissibility [of prior difficulties evidence] is not the number of similarities between the crimes, but whether the evidence of prior incidents was substantially relevant for some purpose other than to show that the defendant likely committed the crime because he is a person of bad character.’ (Citation omitted.) Simmons v. State, 266 Ga. 223, 225(2), 466 S.E.2d 205 (1996).” Sutton v. State, 236 Ga.App. 363, 511 S.E.2d 888 (February 9, 1999). In defendant’s prosecution for kidnapping and rape, evidence of defendant’s prior violent offenses against same victim were admissible as prior difficulties, especially where defendant sought to show that the victim willingly went with him and had sex with him. “Given this defense, evidence of the prior difficulties between Sutton and the victim was admissible. ‘[H]is continuing pattern of abusing and intimidating the victim ... is evidence that he likely abused and coerced the victim on this occasion and that she was too afraid of him to refuse his demands. [Cits.]’ Bohannon v. State, 208 Ga.App. 576, 579-580(2)(b), 431 S.E.2d 149 (1993).” 2. ACTS OF VICTIM Agyemang v. State, 334 Ga.App. 137, 778 S.E.2d 387 (October 8, 2015). Physical precedent only on this point. Simple