In Commonwealth v. Sami, the Commonwealth appealed the trial court’s denial of a motion in limine to admit other acts evidence in a murder case. On appeal, the Commonwealth argued that the admission of drug paraphernalia evidence found in the defendant’s home was admissible under Rule 404(b) to show the defendant had “access to, knowledge of and used those drugs in a way that impacted her state of mind during the double murders.” The Pennsylvania Superior Court affirmed, holding that the Commonwealth failed to show that the disputed evidence of the defendant’s alleged use of methamphetamine and cocaine was relevant. Moreover, the prosecution failed to establish a close factual nexus sufficient to demonstrate the connective relevance between the defendant’s possible possession of cocaine and methamphetamine to the crimes in question.
