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threatening behavior toward defendant’s ex-wife was properly admitted in his prosecution for similar acts in stalking former girlfriend. Accord, Chatfield v. State , 279 Ga.App. 32, 630 S.E.2d 178 (April 19, 2006); Breazeale v. State , 290 Ga.App. 632, 660 S.E.2d 376 (January 23, 2008). Caldwell v. State, 245 Ga.App. 630, 538 S.E.2d 531 (August 22, 2000). False imprisonment and aggravated assault convictions affirmed; trial court properly admitted similar transaction evidence of his prior assault on his 13-year old daughter when she, like the girlfriend/victim in the present case, refused defendant’s demand for oral sex. “Here, because the evidence focused on Caldwell's state of mind when denied a sexual favor, it would tend to prove whether he or the victim had inflicted the victim's wounds. ‘In cases of domestic violence, prior incidents of abuse against family members or sexual partners are more generally permitted because there is a logical connection between violent acts against two different persons with whom the accused had a similar emotional or intimate attachment. A prior act can show the accused's attitude or mindset (i.e., his bent of mind) as to how children or sexual partners should be treated or “disciplined.” A prior act can also show his actual course of conduct in reacting to disappointment or anger in such a relationship, evidencing a pattern.’ (Footnotes omitted.) Smith v. State, 232 Ga.App. 290, 295 (1), 501 S.E.2d 523 (1998). Palmer v. State, 271 Ga. 234, 517 S.E.2d 502 (June 1, 1999). 1. At defendant’s murder trial, defendant’s “prior shootings were similar to the charged crimes and probative of Palmer's method of resolving disputes with family members by shooting at them with a rifle. See Williams v. State, 269 Ga. 827, 829(3), 504 S.E.2d 441 (1998); Willingham v. State, 268 Ga. 64, 64-65(3), 485 S.E.2d 735 (1997); Farley v. State, 265 Ga. 622, 623-624(2), 458 S.E.2d 643 (1995); Edwards v. State, 261 Ga. 509, 509-510, 406 S.E.2d 79 (1991).” 2. Prior assault same night on different victim was admissible to show “bent of mind and motive.” Smith v. State, 237 Ga.App. 852, 521 S.E.2d 7 (April 30, 1999). Defendant’s prior attack against same victim, his wife, was sufficiently similar “for introduction into evidence for purposes of proving Smith's course of conduct and bent of mind. Both incidents involved physical assaults upon his wife's head after arguments, both resulted in serious injuries to her, both were followed by his leaving the location of the incident and his establishment of another explanation for her injuries that negated his responsibility. ‘The rule allowing the admission of similar transaction evidence is usually applied more liberally with evidence of prior attempts by the accused to commit the same crime upon the victim of the offense for which he stands charged. Certain otherwise inexplicable assaults, such as occur in a series of incidents of wife or child abuse, particularly lend themselves to this exception to the “other offenses” rule on questions of both identity and motive.’ (Citations and punctuation omitted.) Parcell v. State, 198 Ga.App. 439(1), 401 S.E.2d 628 (1991). The evidence was properly admitted.’ Herring v. State, 224 Ga.App. 809, 814(4), 481 S.E.2d 842 (1997). See also Smith v. State, 232 Ga.App. 290, 294-295(1), 501 S.E.2d 523 (1998). The fact that the prior offense was a misdemeanor and the one on trial is a felony is not an obstacle to its use for this purpose. See Rodriguez v. State, 211 Ga.App. 256, 258(4), 439 S.E.2d 510 (1993).” Note, more recent cases would dispense with this analysis entirely in cases of prior difficulties between the same parties. See Evidence – Prior Difficulties, above. 35. SIMILARITY OF OFFENSES -- DRUG OFFENSES Owens v. State, 334 Ga.App. 203, 778 S.E.2d 830 (October 20, 2015). Drug possession conviction affirmed; under pre- 2013 Evidence Code, trial court properly admitted similar transaction evidence. “Less than a year prior to the crime for which Owens was being tried, he had been stopped in the same general area, driving the same truck, and was in possession of prescription drugs for which he had no legal prescription or a properly labeled container. Particularly in light of Owens’s defense that he was unaware that the pills were in his truck, evidence of the previous incident was admissible to show Owens’s intent to possess the contraband regardless of the differences in the prescription pills themselves. See Branch v. State, 255 Ga.App. 596, 598, 565 S.E.2d 910 (2002) (‘[T]here is no requirement that the drug allegedly being distributed or possessed in the indicted offense be the same drug distributed or possessed in the similar transaction.’).” Maldonado v. State, 325 Ga.App. 41, 752 S.E.2d 112 (November 20, 2013). Cocaine trafficking convictions affirmed; trial court properly admitted similar transaction evidence. “Here, while the incidents differ in details, the similarities are almost uncanny, showing elaborate distribution schemes involving multiple locations, ‘safe houses,’ vehicles, and couriers, the use of numerous cell phones to direct negotiations and to avoid capture, and the presence of large amounts of cash and cocaine.” Betancourt v. State, 322 Ga.App. 201, 744 S.E.2d 419 (June 12, 2013). Conviction for cocaine trafficking affirmed; trial
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