Are Evidence of Prior Homosexual Relations Relevant In Cases About Sex Crimes Agains Minors ?
In People v. Davis, 260 Ill. App. 3d 176, 631 N.E.2d 392, 197 Ill. Dec. 389 (1994), the defendant, the head pastor of a church, was on trial for offenses connected to various sexual activities in which he had engaged with two boys who were members of his church.
In addition to introducing evidence regarding the defendant's sexual activities with the minor boys, the State introduced evidence that the defendant had engaged in homosexual relations with various adult church members.
Noting the similarities between the defendant's sexual activities with the boys and his sexual activities with adult church members, this court concluded that the evidence of the latter was relevant to establish the defendant's common design, scheme, or plan, although it never defined the nature of that scheme. Davis, 260 Ill. App. 3d at 178-88, 190-91.