People v. Steele
Illinois Supreme Court
174 N.E.2d 848 (1961)

- Written by Sean Carroll, JD
Facts
Stephen Steele (defendant) was charged with offering to sell narcotics to an undercover agent and then selling the agent a different kind of drug without the agent’s knowledge. Specifically, Steele offered to sell agent Robert Jackson heroin but then sold him quinine hydrochloride. At trial, the prosecution (plaintiff) called Jackson to testify. Jackson testified over Steele’s objection that he had previously purchased narcotics from Steele prior to the date in question. Steele’s objection was based on the general rule that evidence of prior crimes is inadmissible to demonstrate the defendant’s character for committing crimes. The prosecution introduced this evidence to prove the required element of deceit in the crime charged. Steele was convicted, and he appealed, arguing that Jackson’s testimony was improper evidence of prior crimes.
Rule of Law
Issue
Holding and Reasoning (Schaefer, C.J.)
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