Are Reports Prepared by a Homicide Victim Containing Details of Previous Drug Contacts and Conversations With Defendant Admissible ?

In Commonwealth v. Russell, 459 Pa. 1, 326 A.2d 303 (1974), the Supreme Court analyzed whether reports prepared by a homicide victim containing references to previous drug contacts and conversations with the defendant were admissible. In acknowledging that evidence of prior criminal activity normally is inadmissible, the Court held that even assuming that the mention of drug involvement implied criminal activity, the evidence was admissible in that case to show the relationship between the defendant and the victim. Id. at 7, 326 A.2d at 306.