What is the test for establishing a defendant's intent and common plan or scheme?

California, United States of America

The following excerpt is from People v. Crow, C081962 (Cal. App. 2017):

establishing defendant's intent and common plan. Although one of the uncharged acts of vandalism did not result in a conviction, the uncharged acts were no stronger or more inflammatory than the charged vandalism. (People v. Tran (2011) 51 Cal.4th 1040, 1047.) In addition, even though there were four witnesses regarding the uncharged offenses, the testimony was brief and took up relatively little time at trial. Accordingly, the trial court properly admitted evidence of defendant's prior acts for the purpose of showing his intent and common plan or scheme.

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