Guill v. Commonwealth
In Guill v. Commonwealth, 255 Va. 134, 495 S.E.2d 489 (1998), the Commonwealth introduced evidence of a 1985 burglary and attempted rape which it argued was sufficiently similar to the charged burglary to show the defendant's intent was to rape. See Guill, 255 Va. 134, 495 S.E.2d 489.
The trial court found the circumstances of the prior crime sufficiently similar to the charged offense and admitted the evidence.
The Supreme Court reversed, noting several factual differences and holding that "evidence of the 1985 crime was inadmissible . . . because that offense was not idiosyncratic in relation to the facts of the present offense. As such, the evidence lacked a logical relationship to the offenses charged and, thus, was irrelevant and showed only the defendant's propensity to commit the crime charged." Id. at 141, 495 S.E.2d at 493.
The Supreme Court held that the defendant's 1985 breaking and entering and attempt to commit rape was unrelated to a 1995 charge of breaking and entering with the intent to rape.
Because "there was no causal relation or logical connection between the 1985 offense and the crime charged," the Supreme Court held that "evidence of the 1985 crime was not probative evidence of the defendant's intent in the crime charged" and was therefore "irrelevant and inadmissible for purposes of proving that intent." Id. at 140, 495 S.E.2d at 492-93.