Com. v. Fowler, N., Com. v. Fowler, N. No. 3722 EDA 2015

On June 7, 2014, Keshiva Poindexter alleged Fowler assaulted her at his home, causing serious orbital injuries and lasting eye damage; she was the sole witness at trial and medical/photographic evidence of injuries was admitted without objection.
Fowler was tried by bench trial, convicted of aggravated assault, simple assault, and recklessly endangering another person, and sentenced to 4½–10 years’ imprisonment.
Pretrial, Fowler obtained a motion in limine allowing defense questioning about a publicly posted video of Fowler to show bias/motive of the victim.
In response, the Commonwealth moved to admit evidence of prior uncharged assaults by Fowler on Poindexter; a pretrial judge admitted two prior incidents (strangulation in summer 2013 and a forehead punch in spring 2014) while excluding other alleged incidents as too remote.
Fowler argued on appeal that admission of those other-acts evidence violated Pa.R.E. 404(b) because it was offered to show propensity rather than a proper purpose; the Commonwealth contended the evidence showed intent, absence of mistake, motive/ill will, and formed part of the “complete story.”
The Superior Court affirmed, finding admission within the trial court’s discretion (probative for intent and absence of mistake and part of the res gestae/complete-story rationale) and, alternatively, harmless error given Poindexter’s testimony and physical evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by admitting evidence of Fowler’s prior uncharged assaults on the victim	Commonwealth: prior assaults admissible to show intent, absence of mistake, motive/ill will, and to complete the story	Fowler: prior acts were only offered to show bad character/propensity and therefore inadmissible under Rule 404(b)	Admission was within discretion: probative for intent/absence of mistake and as part of the "complete story"; alternatively harmless error

Commonwealth v. Patterson, 91 A.3d 55 (Pa. 2014) (standard of review for admission of other-acts evidence)
Commonwealth v. Dillon, 925 A.2d 131 (Pa. 2007) (abuse of discretion standard and relevance/probative balancing)
Commonwealth v. Ulatoski, 371 A.2d 186 (Pa. 1977) (prior abuse admissible to rebut claim of accident)
Commonwealth v. Drumheller, 808 A.2d 893 (Pa. 2002) (prior abuse admissible to show motive, malice, intent, ill will)
Commonwealth v. Lark, 543 A.2d 491 (Pa. 1988) ("complete story"/res gestae rationale for other-acts evidence)
Commonwealth v. Hicks, 156 A.3d 1114 (Pa. 2017) (harmless-error framework for erroneous evidentiary rulings)