State v. Payne (1991)
In State v. Payne, 219 Conn. 93, 98-106, 591 A.2d 1246 (1991), the court considered whether the trial court's admission of evidence of the defendant's subsequent criminal activity to prove identity was appropriate. To uphold the admissibility of the evidence, the court had to determine that it was relevant and that its probative value outweighed its prejudicial effect. Id., 98.
Without making any distinction between prior uncharged misconduct and subsequent uncharged misconduct, the court held that the evidence was not relevant and, therefore, should not have been admitted. Id., 102.