How have the courts treated evidence of past domestic violence in the context of sexual assault cases?

charges against him. " ' " 'The "prejudice" referred to in Evidence Code section 352 applies to evidence which uniquely tends to evoke an emotional bias against the defendant as an individual and which has very little effect on the issues.' " ' " (People v. Branch (2001) 91 Cal.App.4th 274, 286.) In appellant's view, his trial was rendered fundamentally unfair because the evidence of past domestic violence allowed the jury to convict him of the sexual offenses based on the "extraneous factor" of his propensity to commit domestic violence.