People v. . Molineux
168 NY 264, 16 N.Y. Crim. 120, 61 N.E. 286 (1901)
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Rule of Law:
Evidence of a defendant's uncharged, prior crimes is inadmissible to prove the defendant's propensity to commit the crime charged. Such evidence is only admissible if it is logically relevant to establish a material fact in issue, such as motive, intent, absence of mistake or accident, a common scheme or plan, or the identity of the perpetrator.
Facts:
- Roland Molineux and Harry Cornish, members of the Knickerbocker Athletic Club, had a contentious relationship, leading Molineux to resign from the club in December 1897 after failing to have Cornish discharged.
- In the summer of 1897, Molineux met a woman, Blanche Cheeseborough, and later introduced her to another club member, Henry C. Barnet. Barnet and Molineux became rivals for Ms. Cheeseborough's affection.
- On November 10, 1898, Barnet died from what was later determined to be cyanide of mercury poisoning. Nineteen days after Barnet's death, Molineux married Ms. Cheeseborough.
- On December 24, 1898, Cornish received an anonymous package in the mail containing a bottle labeled "Bromo Seltzer" and an accompanying silver bottle holder.
- On December 28, 1898, Cornish's landlady, Katharine J. Adams, complained of a headache.
- Cornish prepared a dose for Mrs. Adams from the Bromo-Seltzer bottle he had received.
- Shortly after drinking the mixture, Mrs. Adams collapsed and died. Cornish, who tasted a small amount himself, became severely ill but survived.
- An autopsy and chemical analysis revealed that Mrs. Adams died from cyanide of mercury poisoning, as the Bromo-Seltzer had been laced with the poison.
Procedural Posture:
- Roland Molineux was charged by indictment with the crime of murder in the first degree for the killing of Katharine J. Adams.
- The case was tried in the Court of General Sessions, a trial court in New York County.
- At trial, the prosecution was permitted, over the defense's objection, to introduce extensive evidence tending to show that Molineux had also committed a prior, uncharged murder of Henry C. Barnet.
- The jury returned a verdict convicting Molineux of murder in the first degree.
- Molineux, as the appellant, appealed the judgment of conviction directly to the New York Court of Appeals, the state's highest court.
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Issue:
Is evidence tending to prove a defendant committed a prior, uncharged murder admissible to prove the defendant's guilt for the murder charged in the indictment?
Opinions:
Majority - Werner, J.
No. Evidence of a defendant's other crimes is generally inadmissible to prove the specific crime charged. The prosecution sought to introduce evidence of the Barnet poisoning to prove Molineux committed the Adams murder, but this does not fall into any of the recognized exceptions. The motive in the Barnet case (jealousy) was distinct from the motive in the Cornish case (hatred), so it doesn't establish motive. The fiendishly clever nature of the poisoning itself established criminal intent, so other-crimes evidence was not needed to prove intent or absence of mistake. The two crimes were not part of a common scheme or plan, but were separate and distinct events. Finally, the mere similarity in the means used (a rare poison) does not sufficiently prove identity without creating undue prejudice, as it serves only to suggest that a person who committed one such crime is likely to have committed the other, which is impermissible propensity evidence.
Dissenting - Parker, Ch. J.
Yes. While agreeing that the conviction should be reversed due to the admission of hearsay evidence, the evidence of the Barnet murder itself should be admissible. The proper test is whether evidence of the other crime fairly aids in establishing the commission of the crime being tried. In this case, the evidence of the Barnet murder was admissible under the identity exception. The unique combination of facts—a rare poison, administration through a common headache remedy, delivery via mail, and the hiring of private letter boxes in the victims' names to procure similar substances—creates a criminal signature. This pattern strongly tends to identify the perpetrator of the Barnet murder as the same individual who attempted to murder Cornish.
Concurring - O'Brien, J.
No. The evidence of the Barnet poisoning was inadmissible. Allowing such evidence violates the principle that a defendant must be tried only for the offense charged in the indictment. To argue that it is admissible to prove 'identity' is just another way of saying that the commission of one crime tends to prove the commission of another. This reasoning is misleading and subverts the protections of the law, as the prejudicial effect of such evidence far outweighs any legitimate probative value. The risk of convicting a defendant based on bad character rather than on evidence of the specific crime is too great.
Concurring - Gray, J.
Yes. While concurring in the judgment to reverse the conviction due to inadmissible hearsay, the evidence concerning Barnet's death was relevant and admissible. It was admissible under the identity exception to the general rule. The combination of rare circumstances, including the specific poison used, its concealment in headache powders, and the use of the mail, showed a 'unity, or similarity, of mental plan and operation.' This evidence, if competently proven, would tend to identify the defendant as the perpetrator of both crimes and should be submitted to the jury.
Analysis:
This is a landmark case in American evidence law, establishing what is now widely known as the 'Molineux rule.' It solidifies the fundamental principle that evidence of a defendant's prior uncharged crimes is generally inadmissible as character or propensity evidence. The court's articulation of the five specific exceptions—motive, intent, absence of mistake, common scheme, and identity—created a durable analytical framework that has been adopted or influential in nearly every U.S. jurisdiction. The decision underscores the high risk of unfair prejudice inherent in other-crimes evidence and mandates a careful, limited application of the exceptions, thereby shaping the contours of criminal trials for over a century.
