People v. Dabbs, 239 Ill. 2d 277

Dabbs was convicted of domestic battery against his girlfriend after a trial in Tazewell County.
DeWeese testified she was battered, with visible injuries; defendant admitted arguing and restraining her.
The State admitted evidence of a prior domestic-violence incident against Dabbs’ ex-wife under section 115-7.4.
Dabbs’ pretrial motion challenged the competency of DeWeese’s testimony; she was found competent to testify with cross-examination allowed.
The jury found Dabbs guilty and the trial court sentenced him to three years in prison.
On appeal, Dabbs challenged section 115-7.4 as unconstitutional, while the appellate court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of section 115-7.4	Dabbs argues it violates equal protection and due process.	Dabbs contends it creates a second-class trial by mandating admission of propensity evidence.	Statute constitutional; permits admissible relevant other-acts evidence if probative value not outweighed by prejudice.
Plain meaning and scope of 115-7.4(a)	Evidence of other domestic-violence acts is admissible whenever offered.	The word is admissible must be read in context; may be misinterpreted as mandatory admission.	“Is admissible” means may be admitted, not mandatory, and requires relevance and balancing against prejudice.
Relation to equal protection and due process standards	Statute aligns with Donoho's equal-protection reasoning.	Propensity evidence is constitutional only with strict limits; the statute may overstep.	Statute serves legitimate purpose and passes rational-basis review; admissibility conditioned on relevance and prejudice balance.

People v. Wilson, 214 Ill.2d 127 (Ill. 2005) (admission may be limited by relevance and prejudice)
People v. Moss, 205 Ill.2d 139 (Ill. 2001) (uses of evidence for motive/intent/identity)
People v. Donoho, 204 Ill.2d 159 (Ill. 2003) (equal-protection concerns with 115-7.3; rational basis for 7.4)
People v. Collins, 214 Ill.2d 206 (Ill. 2005) (statutory interpretation; plain meaning governs)
People v. Davis, 199 Ill.2d 130 (Ill. 2002) (statutory interpretation; use of plain meaning)
Napleton v. Village of Hinsdale, 229 Ill.2d 296 (Ill. 2008) (presumption of constitutionality; narrow construction rule)
Harris v. Walker, 119 Ill.2d 542 (Ill. 1988) (constitutional interpretation; narrow construction of statutes)
Donoho, 396 Ill.App.3d 622 (Ill. App. 2003) (section 115-7.3 not unconstitutional; framework for 7.4)
Illinois Graphics Co. v. Nickum, 159 Ill.2d 469 (Ill. 1994) (statutory interpretation approach; plain-meaning)
Guevara, 216 Ill.2d 533 (Ill. 2005) (due-process standards in criminal procedure)