State v. Mathis
Supreme Court of New Jersey
221 A.2d 529 (1966)
The State (plaintiff) prosecuted Mathis (defendant) for killing Caswell, whose gold and money were missing after the killing. The prosecutor first tried to introduce evidence of Mathis's lack of money and work as proof of motive, but the judge refused to allow it for that purpose. The judge instead allowed the same evidence in for the separate purpose of impeaching Mathis's testimony. The prosecutor then called witnesses whose testimony undercut the impeachment rationale, effectively leaving the financial-need evidence with no valid purpose left standing.
Whether evidence of a criminal defendant's financial need must be relevant to some purpose other than proving the defendant's criminal motive in order to be admitted.