Wednesday, December 18, 2013

Huddleston v. United States case brief

Huddleston v. United States case brief summary
485 U.S. 681 (1988)


CASE SYNOPSIS
Petitioner challenged the judgment of the United States Court of Appeals for the Sixth Circuit, affirming his conviction of possessing stolen property in interstate commerce in violation of 18 U.S.C.S. § 659, on grounds that the trial court improperly admitted evidence of "similar acts" by petitioner under Fed. R. Evid. 404(b).

CASE FACTS
Petitioner challenged his conviction of possessing stolen property in interstate commerce in violation of 18 U.S.C.S. § 659, on grounds that the trial court improperly admitted evidence of "similar acts" involving petitioner's previous sale of stolen televisions, on the issue of petitioner's knowledge, under Fed. R. Evid. 404(b).

DISCUSSION

  • The intermediate court affirmed, and on certiorari, the court affirmed the intermediate court's decision, holding that the trial court properly allowed the evidence to go to the jury. 
  • The court held that the trial court was not required to make a preliminary finding that respondent had proved commission of the similar acts by a preponderance of the evidence. 
  • Rather, the trial court had only to determine that the evidence was offered for a proper purpose under Fed. R. Evid. 404(b), that its probative value outweighed its potential for prejudice under Fed. R. Evid. 403, and that it was relevant. 
  • The trial court properly concluded that the evidence was relevant under Fed. R. Evid. 402, as enforced through Fed. R. Evid. 104(a) and (b), because the jury could reasonably have found, by a preponderance of the evidence, that the televisions were stolen.
CONCLUSION
The judgment was affirmed, because the trial court was not required to make a preliminary finding that respondent had proved commission of the similar acts by a preponderance of the evidence. The trial court properly allowed the evidence to go to the jury, because the jury could reasonably have found, by a preponderance of the evidence, that petitioner committed the similar acts.

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