State of Lousiana v. Isaac Fields, 299 So.3d 126

Defendant charged (Feb. 2, 2018 indictment) with two counts each of first-degree rape and aggravated kidnapping based on assaults on Sept. 19, 1999 and Jan. 6, 2001; DNA from victims’ kits matched defendant via CODIS in 2017.
State filed notice (Oct. 28, 2019) seeking to admit prior-crimes evidence under La. C.E. arts. 404(B) and 412.2; after a hearing the district court excluded ten prior acts and specifically excluded three 1997 armed-robbery charges because those charges resulted in two dismissals and one acquittal.
The three 1997 incidents involved armed robberies of women in Uptown New Orleans where the perpetrator demanded rings/purses while brandishing a firearm; identifications were based on eyewitness lineup/photo identifications, no physical/forensic link.
The district court stated it would not admit evidence of crimes that were dismissed or resulted in acquittal; the State sought supervisory review of the denial as to the three robberies.
The appellate court held the trial court erred to the extent it excluded evidence solely because the prior matters ended in dismissal/acquittal, but on the merits affirmed exclusion because the prior robberies lacked independent relevance, sufficient similarity, and their probative value was substantially outweighed by prejudicial effect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prior act that ended in dismissal or acquittal may be admitted under La. C.E. art. 404(B)	State: Dismissal/acquittal does not automatically bar admission; State need only show sufficient evidence that the defendant committed the prior act (modus operandi/identity).	Defendant: Exclusion proper because prior charges were dismissed or resulted in acquittal.	Court: Trial court erred to exclude solely because of dismissal/acquittal (Cotton, Taylor).
Whether these specific 1997 robberies are admissible as non-character 404(B) evidence (modus operandi/identity)	State: Robberies show a repeated pattern—approaching lone women in Uptown while brandishing a gun and demanding rings/purses—supporting identity/MO.	Defendant: Prior incidents are dissimilar (no sexual assault or kidnapping), different neighborhoods/dates, no physical/forensic link; highly prejudicial.	Court: Evidence inadmissible—lacks independent relevance and sufficient similarity to charged sexual/kidnapping offenses; probative value is substantially outweighed by prejudice (La. C.E. arts. 403, 404(B)).

State v. Cotton, 778 So.2d 569 (La. 2001) (acquittal or dismissal does not automatically bar admission of prior acts under 404(B));
State v. Taylor, 217 So.3d 283 (La. 2016) (State need only show sufficient evidence that defendant committed prior act and must show independent relevancy; trial court must balance probative value against prejudice);
State v. Henderson, 107 So.3d 566 (La. 2013) (trial court must perform 403 balancing when admitting other-crimes evidence);
State v. Langley, 780 So.2d 717 (La. App. 4 Cir. 1996) (discussing admissibility of prior acts/evidence under 404(B)).