People v. Fries

In People v. Fries (1979) 24 Cal.3d 222, the court held that failure to preclude introduction of a prior robbery conviction in a trial for robbery was an abuse of discretion. The court explained People v. Rist (1976) as "emphasizing the extreme caution that trial courts must exercise in deciding to admit a similar prior conviction since the risk of undue prejudice is so great." ( Fries, supra, at p. 230.) Fries focused on the balancing process undertaken by the lower court: "The prior conviction was recent, and under the rules of evidence, admission would be favored. However, a conviction of robbery is only partly relevant to credibility, . . .. Balanced against these two factors was the fact that the robbery conviction was identical to the crime for which appellant was being tried and thus strongly indicated exclusion . . . . para. . . . . para. The second counterbalancing factor favoring exclusion of the prior conviction was that appellant's testimony might have contributed to the jury's understanding of the case, since no other witness testified to a defense version of the facts." ( Fries, supra, at pp. 229-231.)