Howard (defendant) was charged with stealing Alfred Rosenbloom’s wallet at gunpoint near the University of Illinois at Chicago (UIC) campus. At trial, the prosecution called Steven Melamed who testified that Howard had previously stolen his wallet near the UIC campus. The prosecution argued that the Melamed robbery was similar enough to the Rosenbloom robbery to establish Howard’s modus operandi of robberies. Specifically, the prosecution argued that: (1) both robberies were of white male college professors, (2) both robberies occurred on or near the same street next to the UIC campus, and (3) in both robberies the robber came up from behind the victim carrying a gun. Howard claimed that someone else had committed the robberies, and that he was home at the time they were committed. The trial court held that the robberies were sufficiently similar and allowed Melamed’s testimony to help establish Howard’s modus operandi for purposes of identification. Howard was convicted of the Rosenbloom robbery. Howard appealed.