Burke v. State

In Burke v. State 624 P.2d 1240 (Alaska 1980), the Alaska Supreme Court recognized a limited "lewd disposition" exception to Rule 404(b)(1)'s general ban on proving character through evidence of other wrongful acts. Under this exception, which applies in prosecutions for sexual assault or sexual abuse of a minor, the State is allowed to offer evidence that the defendant engaged in other sexual assaults on, or sexual abuse of, the same victim. (See id. at 1248-1250.)