The appellant appealed convictions relating to child pornography and voyeurism, arguing principally that the trial judge improperly admitted and relied on similar fact and disposition evidence without a voir dire.
The court held that the impugned extrinsic evidence concerning the hidden webcam, neighbourhood children, and other voyeuristic recordings was admissible because its probative value on identity and situation-specific propensity outweighed any prejudicial effect.
Count-to-count evidence was also properly used as circumstantial evidence of identity and context.
The court found no prejudice from the absence of a formal admissibility ruling and dismissed the appeal.
