ABSTRACT
The concept of modus operandi has been subjected to extensive analysis through the criminal appeals of serial offenders, and its definition has remained stable. Generally, the terms modus operandi, method of operation, or MO are used interchangeably to describe a certain criminal’s way of operating (State v. Pennell, 1989; State v. Prince, 1992; State v. Code, 1994; State v. Russell, 1994).
