Olds v. the State

Summary

The Supreme Court of Georgia granted a writ of certiorari to clarify Bradshaw v. State's treatment of other-acts evidence admitted under OCGA § 24-4-404(b) to prove criminal intent. It held that although a plea of not guilty makes intent an issue and renders any tendency-bearing other-acts evidence relevant, the conspiracy-case framing imported from United States v. Edouard — that proving intent is invariably a 'substantial burden' meriting near-automatic admission — does not extend to non-conspiracy cases, where Rule 403 demands a careful, case-by-case weighing of probative value against unfair prejudice. Because the Court of Appeals had relied on that confusing framing to affirm the admission of evidence of Olds's assaults on two other women, the Court vacated the Court of Appeals' judgment and remanded for reconsideration, expressly reserving whether the trial court's admissions were an abuse of discretion.