Does Section 1101 of the California Criminal Code allow evidence of prior drug dealing to prove a defendant's propensity or bad character?

Although section 1101 prohibits the admission of evidence of other crimes to prove propensity or bad character, subdivision (b) of section 1101 allows this evidence when relevant to prove some fact such as intent and knowledge. We review the court's evidentiary rulings for an abuse of discretion. (People v. Carter (2005) 36 Cal.4th 1114, 1149.)

Based on the record in this case, we cannot say the trial court abused its discretion in admitting relevant evidence tending to prove a material fact. The evidence of defendant's prior acts fell "within the purview of section 1101, subdivision (b), as it tended to prove [defendant's] knowledge of the narcotic nature of the [methamphetamine], . . . which is an essential element of the crime of selling a narcotic [citations] and [was] probative of his intent to sell it. [Citation.]" (People v. Ellers (1980) 108 Cal.App.3d 943, 953 [in prosecution for sale of heroin, evidence of prior heroin sales admissible to show knowledge of narcotic nature of heroin]; People v. Pijal (1973) 33 Cal.App.3d 682, 691 [in prosecution for selling methamphetamine, evidence of prior drug offenses admissible to show knowledge of nature of drug and intent to sell].)