California, United States of America
The following excerpt is from People v. Kenoth Raymond Bishop, E065543 (Cal. App. 2017):
Admittedly, it has not ruled out a possible exception for the "occasional extraordinary case in which unprotested evidence of past offenses is a dominant part of the evidence against the accused, and is both highly prejudicial and minimally relevant to any legitimate purpose." (People v. Collie, supra, 30 Cal.3d at p. 64.) Even if it were to affirmatively establish such an exception, however, this is not that case. The priors were not a dominant part of the evidence. Moreover, they were substantially relevant for the legitimate purpose of impeachment.
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