Rufo v. Simpson
2001 Daily Journal DAR 945, 103 Cal. Rptr. 2d 492, 86 Cal. App. 4th 573 (2001)
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Rule of Law:
Evidence of a defendant's prior acts of domestic violence against a victim is admissible to prove motive, intent, and identity when the defendant is later charged with a violent crime against that same victim, without needing to show a distinctive modus operandi.
Facts:
- During their marriage, Orenthal James (O.J.) Simpson committed several acts of physical abuse against Nicole Brown Simpson, including a violent argument in 1989 for which he pleaded nolo contendere to spousal abuse.
- On May 22, 1994, Nicole Brown Simpson definitively terminated her relationship with Simpson.
- Following the breakup, Simpson retaliated with financial threats regarding taxes and began stalking Nicole.
- On June 7, 1994, five days before the murders, Nicole telephoned a battered women's shelter, stating she was frightened because her ex-husband was stalking her.
- On June 12, 1994, Simpson attended his daughter's dance recital but was excluded by Nicole from a subsequent family dinner at a restaurant.
- Later that night, Nicole Brown Simpson and Ronald Lyle Goldman were stabbed to death outside Nicole's home.
- Ronald Goldman, a waiter at the restaurant where the family had dinner, was at Nicole's home to return a pair of eyeglasses her mother had left behind.
- Physical evidence found at the crime scene included Simpson's blood, a leather glove matching one found at his residence, and hair fibers consistent with his hair.
Procedural Posture:
- Sharon Rufo and Fredric Goldman, parents of Ronald Goldman, filed a wrongful death action against O.J. Simpson.
- The estates of Nicole Brown Simpson and Ronald Goldman filed survival actions against Simpson.
- The actions were consolidated and tried before a jury in the Superior Court of California for the County of Los Angeles, a trial court.
- The jury found Simpson liable for the wrongful deaths of both victims.
- The jury awarded $8.5 million in compensatory damages to the Goldman parents and a total of $25 million in punitive damages to the two estates.
- Simpson, as the appellant, appealed the judgments to the California Court of Appeal.
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Issue:
Does evidence of a defendant's prior domestic abuse against the same victim fall within the exceptions to the general prohibition on character evidence, making it admissible to prove motive, intent, and identity in a wrongful death action?
Opinions:
Majority - Vogel (C. S.), P. J.
Yes. Evidence of prior domestic abuse against the same victim is admissible under Evidence Code section 1101(b) to prove motive, intent, and identity. The court reasoned that the heightened requirement for a 'distinctive modus operandi' does not apply when the prior acts and the charged crime involve the same perpetrator and the same victim. Citing People v. Zack, the court affirmed that evidence of prior quarrels and assaults between the same parties is obviously relevant to establish motive and identity, preventing the defendant from falsely presenting the relationship to the jury as peaceful. The court also held that Nicole's statements about her fear (in her diary, a letter, and a call to a shelter) were admissible not for the truth of the events described, but for the limited purpose of showing her state of mind, which was relevant to explain her conduct in ending the relationship, which in turn was probative of Simpson's motive.
Analysis:
This decision solidifies a significant exception to the character evidence rule, particularly in the context of domestic violence leading to homicide. It establishes that a history of abuse against the same victim is highly probative of motive and identity, thereby lowering the admissibility threshold that would apply to prior acts against different victims. The ruling prevents defendants in such cases from sanitizing their history with the victim, allowing the jury to consider the full context of the relationship to understand the motive for the crime. This precedent has a substantial impact on both criminal and civil cases involving domestic violence, making it easier to introduce a pattern of abuse as evidence.
