People v. Perez, 2012 IL App (2d) 100865

The State charged Perez with four counts of aggravated criminal sexual abuse tied to victim S.C. and two counts tied to victim D.W., arising from acts before June 1, 2006 and January 20, 2007.
The State moved in limine to admit other-crimes evidence under section 115-7.3 to show propensity; the court allowed it but instructed the State to limit context.
Trial proceeded with severed cases for the two victims; the court later admitted multiple instances of uncharged conduct under 115-7.3, and the jury was given four verdict forms for charged conduct.
Closing arguments and jury instructions discussed charged versus uncharged acts; the court ultimately gave a limiting instruction addressing all other-crimes evidence for limited purposes.
Perez was convicted on the two charged S.C. counts; judgment was entered and he appealed, challenging the admissibility, limiting instructions, and related trial conduct.
The appellate court affirmed, ruling the 115-7.3 evidence was admissible, the limiting instructions were adequate, and any alleged deficiencies did not render the verdicts unreliable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 115-7.3 evidence was admissible and not unduly prejudicial	People contends evidence was probative and properly scoped.	Perez argues volume/prejudice outweighed probative value.	No reversible error; admissions were within 115-7.3 with proper context and limiting scope.
Whether the court failed to give limiting instructions contemporaneously for uncharged conduct	State argues instruction was not required and context was provided.	Perez asserts lack of contemporaneous limiting instructions prejudiced the defense.	No plain error; contemporaneous limiting instructions not required and final limiting instruction given.
Whether the jury instructions and verdict forms properly distinguished charged from uncharged conduct	State asserts the jury was adequately apprised of distinctions.	Perez argues non-differentiated forms risked reliance on uncharged acts.	No plain error; jury was sufficiently told which acts formed the charges and closing clarified scope.
Whether defense counsel was ineffective for not requesting distinguishing instructions	State contends strategies and rulings supported counsel's decisions.	Perez claims failure to request limiting/differentiated instructions prejudiced trial.	No ineffective-assistance; counsel's decisions were reasonable given pretrial rulings and eventual limiting instruction.

People v. Donoho, 204 Ill. 2d 159 ( Ill. 2003) (admissibility and limits of other-crimes evidence; propensity concerns)
People v. Cardamone, 381 Ill. App. 3d 462 (Ill. App. 3d 2008) (extreme volume of uncharged conduct can be undue prejudice)
People v. Walston, 386 Ill. App. 3d 598 (Ill. App. 2008) (joinder and 115-7.3 context; admissibility with context considerations)
People v. Heard, 187 Ill. 2d 36 (Ill. 1999) (limiting instructions not always required during evidence introduction)
People v. Phipps, 238 Ill. 2d 54 (Ill. 2010) (trial court's limiting instructions; strategic decisions)
People v. Herron, 215 Ill. 2d 167 (Ill. 2005) (plain-error review framework)
People v. Tannahill, 152 Ill. App. 3d 882 (Ill. App. 1987) (contextual relevance of evidence in 115-7.3 cases)
People v. Boyd, 366 Ill. App. 3d 84 (Ill. App. 2006) (avoidance of trial within a trial; prejudicial risk of additional evidence)