What is the test for admissible evidence in a criminal case involving an uncharged vehicle burglary?

Appellant contends the uncharged vehicle burglary was not sufficiently similar to the charged offense to render it admissible under Evidence Code section 1101, subdivision (b). But "[t]he least degree of similarity . . . is required in order to prove intent." (People v. Ewoldt (1994) 7 Cal.4th 380, 402.) The uncharged misconduct must only be sufficiently similar to support an inference that the defendant probably harbored the same intent in each instance. (Ibid.) It need not be so unusual and distinctive as to constitute a signature, as is true when an uncharged act is introduced to prove identity. (Id. at p. 403.) Although the 2017 vehicle burglary differed from the charged offense in that it involved forced entry and a completed crime, the jury could infer that appellant had the same intentto enter and steal items from a carwhen he committed each crime.

Our conclusion that the prior vehicle burglary was admissible does not end the inquiry. A trial court admitting

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