Sunday, December 22, 2013

United States v. Carillo case brief

United States v. Carillo case brief summary
981 F.2d 772 (5th Cir. 1993)


CASE SYNOPSIS
United States District Court for the Western District of Texas allowed prosecution to admit extrinsic character evidence of defendant's prior bad acts under identity exception of Fed. R. Evid. 404(b); upon jury conviction for distribution of her*in and c*caine in violation of 21 U.S.C.S. § 841 (1992), defendant sought review.

CASE FACTS
Based on undercover officer's testimony that he purchased narcotics-filled balloon from defendant, jury found defendant guilty of distribution of her*in and c*caine in violation of 21 U.S.C.S. § 841 (1992). At trial, defendant's alibi was mistaken identity. The district court allowed the government to present evidence of two other sales of controlled substances by defendant as modus operandi to help establish his identity as the drug seller. Defendant challenged admission of those extrinsic acts under the identity exception of Fed. R. Evid. 404(b).

DISCUSSION
  • The Court vacated defendant's conviction and remanded for new trial, holding defendant's prior acts did not bear a sufficiently high degree of similarity to the charged offense to mark it as defendant's handiwork. 
  • Such character evidence was not to be excluded because it had no probative value, but because it could lead a jury to convict the accused on the ground of bad character deserving punishment regardless of guilt.
CONCLUSION
Court vacated defendant's conviction, holding defendant's prior bad acts inadmissible because such character evidence did not bear sufficiently high degree of similarity to charged offense marking it as defendant's handiwork, and could lead to jury conviction on ground of bad character deserving punishment regardless of guilt; remanded for new trial.

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