Domestic violence cases have a life of their own. The prosecution routinely proceeds even when the alleged victim recants, does not want charges, or never wanted them in the first place. Protective orders issue immediately and can put someone out of their own home and away from their own children before a single fact has been proven. Defenses are real: self-defense, false allegation, mutual combat, and the frequent reality that the person the police arrested was not the aggressor. Evidence Code § 1109 propensity evidence — prior incidents offered to prove present guilt — is one of the most damaging tools the prosecution has in these cases, and it can be fought.