In People v. Doyle , Shawn Doyle was convicted of second degree murder after the body of his ex-girlfriend -- who had been missing for 10 weeks -- was discovered inside a chest floating in the Champlain Canal .
Around the time she disappeared, Doyle agreed to help his ex-girlfriend move into a new apartment and accompanied her to the bar where she worked. She left the establishment with a patron whom she had been dating and then later reconnected with Doyle. According to reports, Doyle was the last person to see her alive.
The victim had been gagged with a bandana and her mouth had been taped shut. Her hands and feet were handcuffed, her body wrapped in a comforter, and she was stuffed into a trunk along with sand tubes for weight. (An autopsy revealed that she had suffocated.)
After the County Court of Washington convicted Doyle of second degree murder and sentenced him to 25 years to life, Doyle appealed to the Appellate Division, Third Department, claiming that the evidence was legally insufficient and that the verdict was against the weight of the evidence.
But the circumstantial evidence established to the contrary. According to the AD3:
(1) Doyle had purchased the chest less than a week before the victim's disappearance;
(2) the key to the chest was found in his truck's glove compartment;
(3) sand tubes and handcuffs matching those used in the crime were found at Doyle's home;
(4) bandanas found at Doyle's home were similar to the one used to gag the victim;
(5) testimony from Doyle's friend said she had seen the chest in Doyle's car, asked about it, and was told it was for fishing, even though Doyle didn't fish; and
(6) when Doyle stopped at the witness' house after his trip with the victim, Doyle wasn't wearing his bandana.
Doyle's convictions for menacing (after he had pushed and choked a former girlfriend), and for unlawful imprisonment (when he duct-taped the mouth of another former girlfriend, choked and strangled her), together with the abusive nature of his relationship with the victim, were all properly considered. As the AD3 noted:
Evidence regarding (Doyle's) prior abusive and threatening behavior toward the victim herself, while prejudicial, was legally relevant and material to issues aside from (Doyle's) propensity to commit murder, namely, motive, intent, identity and relevant background information, and its probative value in this circumstantial evidence case outweighed its potential prejudice … Prior incidents, which do reveal a sufficiently distinctive crime pattern, were properly admitted to establish defendant's motive and identity as the victim's murderer.

To download a copy of the Appellate Division's decision, please use this link: People v. Doyle