118 U.S.App.D.C. 11, 16, 331 F.2d 85, 90 (1964); accord, Jones, 477 A.2d at 237; Wheeler v. United States, 470 A.2d 761, 769 (D.C. 1983). The proscription against admissibility of evidence of prior criminal acts extends to acts that have not been formally adjudicated as crimes, Wheeler, 470 A.2d at 769; Miles v. United States, 374 A.2d 278, 282 (D.C.1977), but not to acts that are not, at least, “minimally in the nature of a criminal offense,” Wheeler, 470 A.2d at 769; see Jones, 477 A.2d at 237 n. 13. It is by no means certain that appellant’s possession of a large sum of cash at the time of his arrest “in and of itself,” Wheeler, 470 A.2d at 769, was sufficiently criminal in nature to trigger the rule of inadmissibility. See, Hawkins v. United States, 482 A.2d 1230, 1232 (D.C.1984) (<HOLDING>); Wheeler, 470 A.2d at 770 (behavior of
recognizing possession of cocaine as a lesserincluded offense of possession of cocaine with intent to sell holding that a reasonable jury could have concluded based on repeated references to the substance as cocaine and testimony from witnesses who had used the substances which they believed to be cocaine that substance was cocaine holding the imposition of a maximum sentence of life imprisonment was not excessive for conviction of possession of cocaine where defendant was adjudged to be a fourth felony offender with prior convictions for manslaughter two prior convictions for possession of cocaine and numerous arrests for drug offenses possession of a firearm by a felon aggravated battery and armed robbery holding that in prosecution for possession of a controlled substance cocaine possession of cutting reagents used to dilute cocaine and heroin was not other crimes evidence because possession of these substances is legal holding that simple possession of cocaine is not lesser included offense of conspiracy to possess cocaine with intent to distribute