Evidence: 404(b) and Lyle

· State v. Lyle, 125 S.C. 406 (1923) This is the seminal case for discussing prior bad act evidence. The case describes what propensity evidence is and how persuading it can be to a jury. Because of its power, propensity evidence is excluded unless it is being used for another purpose. Lyle lists several exceptions to the rule against propensity evidence, and SCRE 404(b) has codified these exceptions. Lyle requires that any prior bad act that fits in to an exception have a logical connection to the charged crime. It is not enough that the two acts are similar. See State v. Perry, 430 S.C. 24 (2020) for a discussion on this logical connection test and how case law had drifted away from this strict requirement.