Emmanuel Harris was convicted of murdering his girlfriend after claiming he stabbed her in self-defense when she came at him with a knife. The State introduced extensive evidence that Harris had badly injured a former girlfriend, arguing it showed a motive to control partners through violence and rebutted accident or mistake. The Supreme Court of Georgia held that the generic “control through violence” theory was propensity reasoning, while the accident-or-mistake theory had little probative value and the graphic prior-incident evidence was unfairly prejudicial. Because the error was not harmless, the Court reversed Harris’s convictions and remanded for a new trial.