People v. Chapman, 2012 IL 111896

Chapman was convicted of first-degree murder of his girlfriend Cassandra Frazier in Joliet after stabbing her repeatedly.
State admitted evidence of a prior domestic battery against Frazier from October 2003 under 725 ILCS 5/115-20 to prove propensity and intent in the murder prosecution.
Trial court allowed admission of the prior battery and testimony about a 2004 apartment fire set by Chapman as circumstantial evidence of intent.
Defense argued 115-20 does not permit use of a prior domestic battery conviction in a murder case when the victim is the same person and household member.
Jury was instructed that the prior conviction could be considered for relevant matters; Chapman was found guilty and sentenced to 60 years.
Appellate court affirmed; this Court held that section 115-20(a) authorizes admission of a prior domestic-violence conviction in a subsequent prosecution for a type of offense that includes murder in a household setting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 115-20(a) permit admission of a prior domestic battery conviction in a murder prosecution?	Chapman contends murder isn't among enumerated offenses so 115-20(a) cannot apply.	State argues 115-20(a) covers ‘types of offenses’ broad enough to include murder when victim is same.	Yes; 115-20(a) covers murder as a type of offense.
What constitutes 'types of offenses' under 115-20(a) and does it extend beyond enumerated crimes?	Narrow interpretation restricts to enumerated offenses.	Statute broad enough to include offenses of the same kind against the same victim.	Types include offenses of the same kind as enumerated; murder in domestic-violence context qualifies.
Was the trial court’s admission of the prior domestic battery and Ware’s testimony within the evidentiary discretion?	Admission overly prejudicial or improper under common-law limits.	Evidence has probative value for intent and propensity, outweighing prejudice.	Yes; court did not abuse discretion; evidence admissible for intent/propensity.

People v. Dabbs, 239 Ill. 2d 277 (2010) (propensity rule abrogated by statute when probative and not unduly prejudicial)
People v. Ward, 2011 IL 108690 (Ill. 2011) (propensity evidence under 115-7.3 similar to 115-20 analysis)
McCarthy v. People, 132 Ill. 2d 331 (1989) (prior domestic-violence acts admissible to show intent to harm victim)
People v. Wilson, 214 Ill. 2d 127 (2005) (common-law admissibility of other-crimes evidence; purposes beyond propensity)
People v. Illgen, 145 Ill. 2d 353 (1991) (admissibility framework for other-crimes evidence)