Although the rules and exceptions regarding the admissibility of evidence of prior misconduct during criminal trials are well established, the theories and logic underlying the black letter law have apparently eroded to mere words. State v. Sladek' and State v. Bernard were two recent opportunities for the Missouri Supreme Court to examine the law of uncharged misconduct evidence. Unfortunately, the majority opinions in these cases did not address the central problems with this area of evidence but instead, they sidestepped the issues and created a new unprincipled exception The new exception, signature modus operandi/corroboration, ignores the central reason that prior uncharged misconduct evidence is inadmissible: the prejudicial and irrelevant nature of character evidence when prosecuting a particular crime. This Comment will discuss the Sladek and Bernard cases, the adoption of the new exception, and the disparities in the exception's application between the districts.

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