Bigpond v. State, 270 P.3d 1244

Bigpond charged with battery constituting domestic violence, third offense within seven years.
State sought to admit evidence of prior domestic violence involving Bigpond and the victim, arguing for contextual/nonpropensity purpose.
District court conducted Petrocelli hearing and admitted the prior acts with a limiting instruction after victim recanted pretrial statements.
Bigpond was convicted; appellate review focused on admissibility under NRS 48.045(2) for nonpropensity purposes beyond listed examples.
Nevada Supreme Court held that evidence of other crimes may be admitted for any relevant nonpropensity purpose, overruling prior broad-characterizations and affirming the conviction.
Court cautioned that such evidence carries a presumption of inadmissibility and must meet three Tinch factors with a limiting instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NRS 48.045(2) allows nonpropensity use beyond listed purposes.	Bigpond argues the statute excludes such use beyond its list.	State contends it can admit for legitimate nonpropensity purposes.	Yes; admissible for relevant nonpropensity purpose beyond listed purposes.

State v. McFarlin, 41 Nev. 486 (1918) (broad rule of exclusion with narrow exceptions (origins of rule))
Rowbottom v. State, 105 Nev. 472 (1989) (prior relationship evidence admissible under Rule 404(b) context (overruled partly))
Willett v. State, 94 Nev. 620 (1978) (discussed broad vs. narrow rule of exclusion)
Theriault v. State, 92 Nev. 185 (1976) (early broad exclusion approach (overruled in part))
Braunstein v. State, 118 Nev. 68 (2002) (acknowledged nonpropensity purposes beyond listed in NRS 48.045(2))