In People v. Deeney (1983) 145 Cal. App. 3d 647, the defendant was convicted of involuntary manslaughter for the death of his wife. There was evidence that the wife's fatal hemorrhage probably resulted from a fall instead of from a blow. Evidence showed the wife was an alcoholic who was prone to stumbling. The trial court admitted evidence that on more than one occasion the defendant dragged his partially-clothed wife outside and sprayed water on her while yelling obscenities. The court also admitted evidence of bruises on the wife's body in the weeks before her death. No witness ever saw the defendant hit the victim, although evidence was admitted that the wife said he did. ( Id. at pp. 650-651.) The Court of Appeal held that the wife's hearsay statements and evidence of the defendant's prior conduct both were erroneously admitted and prejudicial. ( People v. Deeney, supra, 145 Cal. App. 3d at p. 651.) However, the court conceded that the evidence could have been admitted to rebut the defendant's assertion of accidental death. Because the jury could infer that the defendant had caused the victim's previous injuries, the evidence weakened the defendant's assertion that the victim's death was a result of accidental injuries. ( Id. at p. 655.) As such, the evidence was probative of a material issue at trial. ( Id. at p. 656.)