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prejudice or confusion was low. [fn] Accordingly, the trial court did not abuse its discretion in overruling Mitchell's relevance objection.” Cantera v. State, 304 Ga.App. 289, 696 S.E.2d 354 (June 3, 2010), affirmed on other grounds, 289 Ga. 583, 713 S.E.2d 826 (June 27, 2011). At defendant’s trial for voluntary manslaughter and related offenses, trial court properly admitted evidence that defendant killed victim because victim revealed that defendant had previously killed defendant’s wife to collect life insurance proceeds. Trial court also properly admitted “Cantera's prior admissions that he had his wife killed[,] in order to show that Cantera's children were involved in litigation over the insurance policy based on a legitimate desire to insure that their father was not rewarded for taking their mother from them.” Defense introduced the subject of the insurance litigation to impeach the children, who were State’s witnesses; State was thus properly allowed to explain why they filed suit against defendant. Young v. State, 281 Ga. 750, 642 S.E.2d 806 (March 26, 2007). Prior shooting was admissible in defendant’s murder trial because it provided the motive for his shooting of victim here – defendant was afraid second victim might ‘turn snitch’ on him on the first shooting. Although often referred to as similar transactions, including USCR 31.3, “in fact, the concept is as stated in Williams [ v. State, 261 Ga. 640 (409 S.E.2d 649) (1991)]; what is at issue is the admission of evidence of ‘independent offenses or acts.’ Williams, supra at 642(2)(b). And, as Williams states, the third showing that the State must make is ‘that there is a sufficient connection or similarity between the independent offense or act and the crime charged so that proof of the former tends to prove the latter.’ Id. (Emphasis supplied). In this case, it is not the similarity between the two transactions that is relevant, but the connection between the two. The question is whether the State showed that there was a connection between the offenses such that ‘proof of the former tends to prove the latter.’ Id. The required connection is embedded in the proffered motive; the killing of Arkeem was committed to prevent evidence from being produced as to Young’s involvement in the Spurgeon shooting. And, the connection is adequately shown in the State’s proffer. [fn] The same handgun, linked to Young, was used in both murders. Young had fought with another cousin, Daniel Young, and called him a ‘snitch’. … Young’s willingness to do violence to another cousin over the matter shows his willingness to believe that members of his family were potential threats to him regarding his involvement in the Spurgeon killing, and there was no other discernible motive for Young’s shooting of Arkeem. [fn] The State’s proffer shows that there is a connection ‘in the mind of the actor, linking [the two killings] together for some purpose he intended to accomplish.’ Cawthon v. State, 119 Ga. 395, 396(5) (46 S.E. 897) (1904).” See also Cummings (March 19, 2001), below. Inman v. State, 281 Ga. 67, 635 S.E.2d 125 (September 18, 2006). In defendant’s trial for murder and armed robbery, trial court properly admitted evidence of defendant’s prior charge of cocaine possession with intent to distribute, from California. “ The trial court admitted the testimony as tending to show [defendant’s] motive for committing the crimes for which he was being tried, i.e., his need to acquire funds to become involved in the illegal drug trade in Adel. ‘While motive is not an essential element in the proof of the crime of murder, the motive and evidence which is relevant to an issue in a case is not rendered inadmissible by the fact that it incidentally puts the defendant’s character in issue. [Cit.].’ Morgan v. State, 276 Ga. 72(6) (575 S.E.2d 468) (2003). Consequently, the trial court did not err in permitting the testimony.” Fulton v. State, 278 Ga. 58, 597 S.E.2d 396 (June 7, 2004). Evidence that defendant had committed a similar robbery the night before was admissible though not noticed as a similar transaction, because the prior offenses allegedly supplied the motive for the offenses on trial: defendant believed the second victim was hired to kill him by the first victim. Cummings v. State, 273 Ga. 547, 544 S.E.2d 429 (March 19, 2001). The Supreme Court affirmed the defendant’s conviction for malice murder. Held, that the trial court properly admitted evidence of the Defendant’s involvement in a prior murder without requiring the state to comply with Uniform Superior Court Rule 31.3. The evidence was relevant to show that the Defendant had a motive in killing the victim, who snitched to the police about the other murder. Further held, the fact that the trial court did not allow use of the evidence as a similar transaction did not stop admission of the evidence for another purpose. See also Young (March 26, 2007), above. Adams v. State, 272 Ga. 115, 527 S.E.2d 200 (February 28, 2000). Malice murder and armed robbery convictions affirmed. Trial court properly admitted evidence of prior dispute between defendant and victim which ended with defendant shot at the police and punched victim. Adams went to prison as a result. “The State demonstrated that Adams blamed [victim] Cleghorn for the prior incident; and that, at the time of the murder, he still begrudged Cleghorn because of it. Thus, the prior incident constituted evidence of motive, and it cannot be said it was irrelevant or remote in time.”

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