Relevancy: "Context," "Circumstances," and "Chain of Events" Evidence

In an earlier post, I wrote about relevancy and guilt of another. In this post, I consider another relevancy issue: context, circumstances, and chain of events evidence. Consider this problem: At the defendant’s murder trial, the State seeks to admit evidence that the defendant was doing drugs before the murder. To keep the facts clean, assume that voluntary intoxication is not a defense. The defense lawyer wants to keep evidence of the defendant’s drug use out because it paints the defendant as a bad person. Defense counsel makes a Rule 401 objection, arguing that the drug use is irrelevant. The State responds, arguing that the evidence is relevant because a tip about the defendant’s drug use caused the officers to do a knock and talk that resulted in the defendant’s confession to the murder. How should the judge rule? The objection is likely to be overruled. Evidence is relevant if it establishes the context or circumstances of an event or if it explains a chain of events. This rule sometimes is called the “same transaction” rule, the “complete story” rule, or the “course of conduct” rule. State v. Sexton, 153 N.C. App. 641 (2002). Chain of circumstances evidence “is admissible if it forms part of the history of the event or serves to enhance the natural development of the facts.” Id. Significantly, such evidence is relevant even if it incidentally establishes commission of a prior bad act (in my example, drug use). Id. When the chain of events evidence reveals a [...]