How has the court treated evidence of prior "pick-up fights" and threatened a police officer?

While evidence defendant had previously "pick[ed] fights" and threatened a police officer was potentially prejudicial (see People v. Karis (1988) 46 Cal.3d 612, 638 [[Evidence Code]section 352 is designed to avoid evidence uniquely tending to evoke emotional bias against the defendant as an individual that has very little effect on the issues]), the trial court acted within its discretion under Evidence Code section 352 in determining the probative value outweighed prejudicial effect. Based on the similarities, the probative value was substantial. The jury was instructed not to consider the evidence to establish disposition or propensity. Defendant's prior conduct was not egregious or inflammatory. Additionally, defendant mitigated any potential prejudice by crossexamining Drake concerning his use of force during the encounter at the jail, which resulted in defendant's transportation to a hospital. Finally, the jury did not appear unduly influenced by the evidence because it acquitted defendant of the charged, greater offense and found he had not committed the brandishing offense. We discern no abuse of discretion.

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