☢ test - Í

commented on the woman’s appearance, asked the woman to look at him, and began masturbating in her presence. Although he also groped the victim’s breast in this case, proof of the Colorado incident tended to establish the charged offense.” Howard v. State, 287 Ga.App. 214, 651 S.E.2d 164 (August 10, 2007). “Howard’s prior sexual abuse of a young male relative is sufficiently similar to the sexual abuse of a young female relative for which he was on trial to make evidence of that prior abuse admissible” as a similar transaction. Accord, Gunn v. State , 300 Ga.App. 229, 684 S.E.2d 380 (September 25, 2009). Washington v. State, 286 Ga.App. 268, 648 S.E.2d 761 (July 3, 2007). 1. In defendant’s prosecution for rape and aggravated sodomy of 16-year old, defendant’s prior conviction for child molestation was sufficiently similar for admission as similar transaction. 2. Certified copy of prior conviction was sufficient to show similarity of sexual offenses. “The only testimony about the earlier crime came from the investigating officer, who identified Washington as the defendant, but did not provide any details of the crime.” Distinguishing Williams v. State, 261 Ga. 640, 652(2)(d) (409 S.E.2d 649) (1991) and Stephens v. State, 261 Ga. 467, 469(6) (405 S.E.2d 483) (1991), both involving drug offenses. “In cases decided after Williams and Stephens, this Court has held that, because of the liberal admission of similar transaction evidence in cases involving sexual offenses, especially those against children or teenagers, ‘a certified copy of a prior conviction for a sex crime against a child may, with no other evidence, sufficiently prove that the prior crime is similar to the current crime.’ Lee v. State, 241 Ga.App. 182, 183(2) (525 S.E.2d 426) (1999) (certified copy of conviction for raping a 15 year old girl adequately proved similarity of that rape to the rape of 12 year old victim); see Parker v. State, 283 Ga.App. 714, 721(3) (642 S.E.2d 111) (2007) (certified copy of indictment and guilty plea were adequate to prove similarity between touching of 13 year old victim’s breast and vagina and fondling the breast of a child under 14).” Maynard v. State, 282 Ga.App. 598, 639 S.E.2d 389 (November 29, 2006). Defendant/police officer’s conviction for aggravated child molestation reversed; the trial court erred by allowing the State to submit similar transaction evidence of a very different sexual offense from his youth. “The record on appeal shows that 31-year-old Maynard, a former police officer, was charged with three counts of child molestation and statutory rape involving a fifteen-year-old victim, who was part of a police-affiliated Scout program.” The similar transaction evidence showed “that when Maynard was around 12 years old he initiated sexual contact with one male cousin who was approximately nine or ten and attempted sexual contact with another male cousin who at the time was six or eight years old. The sexual contact was oral sodomy and anal intercourse.” Held, the evidence here was too dissimilar: “In Tyson v. State, 232 Ga.App. 732, 733(1) (503 S.E.2d 640) (1998), this court held that ‘[a]lthough in other sexual abuse cases this Court has allowed the admission of similar transaction evidence which was more than 20 years removed from the present offenses, our review of those cases shows they involve either a continuous course of criminal conduct, often involving different generations of the same family, or situations in which the defendant has been incarcerated for some of the intervening time.’ … Here, however, the prosecution showed neither a pattern of continuous conduct, nor that Maynard was incarcerated for any part of the period. Additionally, we must note that Maynard was a child himself at the time of the events described by his cousins, but was an adult 20 years later at the time of the events in these charges, and the prosecution offered no evidence of any alleged sexual misconduct in the intervening years. Under the circumstances, the similar transaction evidence offered by the prosecution was not admissible. Tyson v. State, supra, 232 Ga.App. at 733(1).” Attaway v. State, 279 Ga.App. 781, 632 S.E.2d 397 (May 12, 2006). Prior offense was sufficiently similar. “The victims of the current child molestation and Attaway’s prior offense were both young girls whom Attaway knew. And in both instances, while Attaway was alone with the girls, he placed his hands on their vaginal areas.” Cases differed in that prior offense also involved solicitation of sodomy. Accord, Parker v. State , 283 Ga.App. 714, 642 S.E.2d 111 (January 18, 2007). Robbins v. State, 277 Ga.App. 843, 627 S.E.2d 810 (February 13, 2006). “‘In the area of sexual offenses, the admissibility of similar transaction evidence is liberally construed. In addition, when forcible sexual assaults are involved, there is at least much sociological evidence to support the conclusion that this type of deviant sexual behavior is a sufficiently isolated abnormality so that proof of the propensity of the defendant to engage in it is at least admissible, and to this extent proof of the one tends to establish the other.’ (Citations and punctuation omitted.) Wagner v. State, 253 Ga.App. 874, 875-876(1)(a), 560 S.E.2d 754 (2002).” Accord, Harmon v. State , 281 Ga.App. 35, 635 S.E.2d 348 (August 10, 2006); Ford v. State , 281 Ga.App. 114, 634 S.E.2d 391 (August 14, 2006); Watley v. State , 281 Ga.App. 244, 635 S.E.2d 857 (August 23, 2006). “ In a prosecution for rape, the prior assault need not have resulted in an actual