Recently, in State v. Morrow 299 Or App 31 (2019), the Oregon Court of Appeals ruled that a defendant’s prior uncharged acts of domestic violence were not admissible to show motive. Trial courts must be on guard, Justice Aoyagi explained, to prevent the motive label from being used to smuggle forbidden evidence of propensity to the jury. Presiding Justice Hadlock dissented, arguing that defendant’s pattern of resorting to violence whenever the victim failed to comply with his demand that she leave their shared space was a ‘specific motive’ that went beyond general hostility. I suspect Hadlock’s argument will ultimately prevail, but for now, Morrow is good law.