Old Chief v. United States case brief (130 S. Ct. 563)

Old Chief v. United States 130 S. Ct. 563

FACTS
The defendant, a felon, was arrested after an incident involving the firing of a gun. The defendant was charged with various crimes including violating 18 U.S.C. Section: 922(g)(1) making it a crime for anyone “who has been convicted in any court of, a crime punishable by imprisonment for a term exceeding one year” to “possess in or affecting commerce, any firearm.    

RULES
“In this case, as in any other in which the prior conviction is for an offense likely to support conviction on some improper ground, the only reasonable conclusion was that the risk of unfair prejudice did substantially outweigh the discounted probative value of the record of conviction, and it was an abuse of discretion to admit the record when an admission was available.”   

APPLICATION
-Prior conviction was an element of the charge.  The prosecutor has to prove that OC was convicted for assault causing serious injury.
-Defense attorney offered to stipulate to the prior conviction; prosecutor rejected the offer.  

a.  He wanted the jury to hear about the prior crime, which would mean a greater chance of conviction.

-Defense argues: type of felony is irrelevant to the case at hand, so should not be admissible.  

HOLDING
Rejected OC’s argument.

a.  A trial is not a serious of stipulations - the jury expects to have some meat.

b.  Party autonomy.  The parties should not be denied their chosen method of proving their case just because the other side will stipulate to things that they cannot avoid.  

i.  Autonomy concern is involved in having an adversarial system in the first place.

c.  There is a need for narrative richness.  

i.  Party cannot be confined to proving their case only in a logical way, but also an emotional way.

ii.  If you force a litigant to accept a stipulation in lieu of what the jury expects from the evidence, the jury may wonder what’s being held back.

Second Issue in the case, dealing with prejudicial aspect of prior crime evidence:

Holding: Evidence of a prior felony should have been excluded because the danger of prejudice was substantial (bad character reasoning).

i.  FRE 404(b) - prior criminal acts.

ii.  Defendant’s offer to stipulate to the crime didn’t negate the relevance of the evidence, however it made it so the trial judge abused his discretion in not excluding the prejudicial evidence.  

-Defendant’s prior crime is not a part of the narrative the prosecutor is allowed to tell in trying the defendant for the current crime.  Concern for narrative richness is outweighed. 

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