People v. Collie

In People v. Collie (1981) 30 Cal.3d 43, the defendant was charged with attempting to murder his wife, and evidence of his prior acts of violence against her was admitted. The Supreme Court rejected the defendant's claim that the trial court erred by failing to give a limiting instruction sua sponte. The court stated, "There may be an occasional extraordinary case in which unprotested evidence of past offenses is a dominant part of the evidence against the accused, and is both highly prejudicial and minimally relevant to any legitimate purpose. In such a setting, the evidence might be so obviously important to the case that sua sponte instruction would be needed to protect the defendant from his counsel's inadvertence. But we hold that in this case, and in general, the trial court is under no duty to instruct sua sponte on the limited admissibility of evidence of past criminal conduct." (Id. at p. 64.)