State v. Pirtle
In State v. Pirtle, 127 Wn.2d 628, 669-70, 904 P.2d 245 (1995) the Court faced with the issue of "exactly how much data about a prior conviction are admissible in the State's penalty phase case." Pirtle, 127 Wn.2d at 670.
The State sought to admit evidence of a prior conviction for assault by way of a certified copy of the information charging the prior crime.
The information established the assault was accomplished by use of a "'weapon, namely, a glass, by hitting Chris Mabrey in the face with the glass causing severe lacerations to his face.'" Id. (quoting State's Ex. 191).
The Court asked whether admission of these additional facts contained in the information caused Pirtle undue prejudice.
The Court determined they did not, stating the information may have more probative value as the defendant's criminal history when there are alternative means of committing the same crime, because it shows what means were actually used by the defendant.
Assault, the crime at issue here, can be committed in a number of different ways.
The information here did little more than to inform the jury that this assault resulted in substantial bodily harm and involved the use of a deadly weapon. . . . The information simply stated the particular elements of the crime which was the basis for the conviction. Pirtle, 127 Wn.2d at 670-71.
Thus the Court concluded
It is difficult to see how an information setting forth the name and elements of a charged crime is inherently more prejudicial to the Defendant than the judgment and sentence normally admitted . . . .
Bartholomew does not prohibit the introduction of this information, which simply stated the particular elements of the crime which was the basis for the conviction. Id.