Donahue v. Commonwealth
In Donahue v. Commonwealth, 225 Va. 145, 154-55, 300 S.E.2d 768, 773-74 (1983) the defendant was charged with possession with intent to distribute PCP after police officers executed a search warrant at the residence she occupied with her "husband" and found PCP in the residence.
At trial, the court admitted evidence that on a prior occasion PCP had been seized from her when she was arrested along with others who were seen handling PCP in an automobile.
The trial judge also admitted evidence that when she was arrested for the prior possession of PCP, she confessed to selling it.
The court admitted evidence of the prior possession to prove that she was aware of the presence and nature of the PCP seized from her residence and knowingly possessed it with the intent to distribute.
In reversing the conviction for erroneously admitting the other crimes evidence, the Supreme Court held that the evidence of prior possession of PCP was unrelated to the charged crime and did not tend to prove that Donahue possessed PCP with the intent to distribute. See Donahue, 225 Va. at 156, 300 S.E.2d at 774.