Is there any case law where a defendant has been found guilty of a charge under section 1109 of the California Criminal Code of Civil Procedure for domestic violence prior to the charge being brought against him?

A trial court's determination of the admissibility of evidence of uncharged offenses, being essentially a determination of relevance, is generally reviewed for an abuse of discretion. (People v. Kipp (1998) 18 Cal.4th 349, 369.)

Here, while defendant contends his priors had minimal probative value, the trial court found the prior acts were probative because they were similar to the charged offenses and showed a pattern of violence against a domestic partner. This pattern of domestic violence is precisely the rationale for admitting propensity evidence under section 1109. (See People v. Johnson, supra, 77 Cal.App.4th at p. 419, quoting legislative history [" 'The propensity inference is particularly appropriate in the area of domestic violence because on-going violence and abuse is the norm in domestic violence cases' "].) Thus the trial court made the necessary interest of justice finding, when it determined the remote priors were "more probative" and "not prejudicial."