Is a defendant's past criminal convictions admissible as evidence of criminal misconduct?

Defendant claims counsel rendered ineffective assistance in failing to object to the admission of defendant's misdemeanor convictions. People v. Wheeler (1992) 4 Cal.4th 284 held that a misdemeanor conviction itself when offered for impeachment is hearsay not within any exception (id. at pp. 297-300) but past misdemeanor conduct showing moral turpitude may be admissible. (Id. at pp. 290-295.) Wheeler explained, "Our holding is a narrow one, confined to the specific issue whether under current law a misdemeanor conviction is admissible as direct evidence of criminal conduct. Nothing in the hearsay rule precludes proof of impeaching misdemeanor misconduct by other, more

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