are hard to reconcile on this point”). The test for admissibility in this circuit and elsewhere has long been more permissive: whether the defendant’s conduct in prior crimes is “sufficiently analogous to support an inference” that the defendant intended to do something similar later. See United States v. Benton, 852 F.2d 1456, 1468 (6th Cir.1988). That is functionally the test the district court applied here. Thus, in United States v. LeCroy, 441 F.3d 914 (11th Cir.2006), the court upheld the admission of evidence that the police found notes in the defendant’s car saying that he planned to “rob ears and kill people” and “rape rob and pillage” as evidence that he intended to cause harm during a carjacking 10 years later. Id. at 918, 926; see also Benton, 852 F.2d at 1459, 1467-68 (<HOLDING>). The two offenses in LeCroy were no more
holding that acquiescence required proof that the government willfully accepted the torturous activity or consented to it holding that the government could introduce evidence that a sheriff had accepted kickbacks to protect bootleggers to prove that the sheriff later accepted kickbacks for the purpose of protecting a cocainedistribution scheme holding that on resentencing following reversal the state was required to introduce evidence to prove the defendant qualified for an enhanced sentence and could not only rely upon evidence introduced at a prior sentencing hearing holding that the government must prove the facts used in sentencing by a preponderance of the evidence holding that the government may not introduce evidence obtained through violations of the fourth amendment