United States v. Guardia case brief

United States v. Guardia case brief summary
135 F.3d 1326 (10th Cir. 1998)

CASE SYNOPSIS

Prosecution appealed from a judgment of the United States District Court for the District of New Mexico, which in proceedings prior to defendant's criminal trial, excluded evidence pursuant to Fed. R. Evid. 413.

CASE FACTS
Prior to defendant's trial, the trial court excluded evidence from four women who alleged that defendant abused them in ways similar to the facts in the case against defendant.

DISCUSSION

• On review, the court held that rule 413 superseded rule 404(b) which provided a general exclusion for propensity evidence such as that in the case at issue. 
• The court then held that the balancing test under rule 403 was applicable to evidence that fit within the ambit of rule 413. 
• Additionally, the court concluded that the trial court did not abuse its discretion in determining that the probative value of the evidence was substantially outweighed by the danger of unfair prejudice. In reaching its conclusion, the court held that nothing indicated that a more lenient balancing test should be applied to evidence under rule 413.

CONCLUSION
The court affirmed the order excluding the evidence in defendant's case.

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