How have the courts treated prior convictions in a sexual assault case?

The issue of the prior convictions was never again raised by defense counsel during the trial. Defendant now argues the trial court applied the wrong standard in addressing the victim's prior convictions. He argues the court applied an analysis pursuant to People v. Castro regarding the prior convictions when the defense sought to introduce the priors as "other crimes evidence offered to show propensity under section 1101." The People counter, correctly, that the admission of propensity to demonstrate a victim acted in conformity with a character trait is governed by section 1103, not section 1101. The People assert defendant never raised this theory in the trial court, thus the issue has been forfeited on appeal. Defendant replies:

We agree with the People that defendant's contention is not cognizable on appeal.