People v. Howard
Court of Appeals of Illinois
708 N.E.2d 1212 (Ill.App. 1999)
Charged with robbing Alfred Rosenbloom's wallet at gunpoint near the University of Illinois at Chicago campus, Howard (defendant) had the prosecution introduce testimony from Steven Melamed describing an earlier, similar robbery, arguing the two robberies — both of white male college professors, both occurring on or near the same UIC-area street, and both involving an armed approach from behind — established Howard's distinctive modus operandi for identification purposes. Howard claimed mistaken identity and an alibi, but the trial court admitted Melamed's testimony, and a jury convicted Howard of the Rosenbloom robbery; he appealed.
Whether testimony about a prior robbery sharing generic similarities common to many armed robberies — similar victim demographics, similar location, and similar approach tactics — is sufficiently distinctive to establish a defendant's modus operandi for identification purposes.