In a circumstantial homicide case where evidence of the accused's prior violence towards the victim is admitted as relationship evidence relevant to intention and to rebut accident, a propensity warning is not necessarily required and may in fact confuse the jury's legitimate reasoning process. The need for a propensity warning is not universal and depends on the circumstances of the case. Evidence of prior acts of violence towards a homicide victim is admissible not merely as 'background' but as evidence of animosity relevant to intention, to rebut accident, and as part of the circumstantial case.
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