United States v. Hearst
United States Court of Appeals for the Ninth Circuit
563 F.2d 1331 (9th Cir. 1977)
Patty Hearst (defendant) was charged with bank robbery and raised a duress defense, claiming her codefendants forced her to participate. Over her objection, the prosecution introduced evidence that about a month later she took part in another robbery, where she waited in the getaway car and fired a rifle to help a codefendant escape capture, and in a kidnapping, where the victim testified she did not flee when she had the chance. The jury convicted Hearst, and she appealed the admission of this other-crimes evidence.
Whether evidence that a defendant committed other crimes shortly after the charged offense is admissible to prove the defendant's intent, where the defendant has raised a duress defense putting her intent at issue.