Admissibility of Evidence of Other Crimes

"Where a course of criminal conduct is continuous and interwoven, consisting of a series of related crimes, the perpetrator has no right to have the evidence 'sanitized' so as to deny the jury knowledge of all but the immediate crime for which he is on trial." Scott v. Commonwealth, 228 Va. 519, 526, 323 S.E.2d 572, 577 (1984).

"The fact-finder is entitled to all of the relevant and connected facts," including those which occurred before or after the crime charged, "even though they may show the defendant guilty of other offenses." 228 Va. at 526-527, 323 S.E.2d at 577.

See Kirkpatrick v. Commonwealth, 211 Va. 269, 276, 176 S.E.2d 802, 807-08 (1970).

Evidence of other crimes, which are "so intimately connected and blended with facts proving the commission of the offense charged," may be admissible because "it cannot be separated with propriety." Sutphin v. Commonwealth, 1 Va. App. 241, 246, 337 S.E.2d 897, 899 (1985).

The probative value of that evidence explaining the defendant's conduct and completing the story of the transaction "outweighed any incidental prejudice to the defendant in the form of evidence that the defendant may have been involved in other drug distributions." Newton v. Commonwealth, 29 Va. App. 433, 454, 512 S.E.2d 846, 856 (citing Scott, 228 Va. at 526-27, 323 S.E.2d at 577), cert. denied, 120 S. Ct. 540, 145 L. Ed. 2d 419 (1999).