Sunday, December 22, 2013

United States v. Wong case brief

United States v. Wong case brief summary
703 F.2d 65 (3d Cir. 1983)

Defendant challenged a judgment from the United States District Court for the Eastern District of Pennsylvania, which convicted him for mail fraud and medical fraud. Defendant argued the discretion to exclude, as unduly prejudicial, evidence that defendant had previously been convicted of a crime involving dishonesty or false statement.

Defendant was charged with 17 counts of mail fraud and 2 counts of violation of the Racketeer Influenced and Corrupt Organizations statute. At trial, the state sought to use defendant's prior convictions for mail fraud and medicare fraud for impeachment purposes. Defendant argued that the apparent mandatory admission of crimen falsi under Fed. R. Evid. 609(a)(2) was qualified by the general balancing test of Fed. R. Evid. 403. The district court allowed the two prior convictions into evidence without conducted the balancing test of whether the probative value outweighed their prejudicial effect.


  • On appeal, the court held that the general balancing test of Fed. R. Evid. 403 was not applicable to impeachment by crimen falsi convictions under Fed. R. Evid. 609(a)(2). 
  • The court reasoned that Fed. R. Evid. 403 was not designed to override more specific rules; rather it was designed as a guide for the handling of situations for which no specific rules have been formulated. Fed. R. Evid. 609(a) was such a specific rule. 
  • The court concluded that judges were to have no discretion to exclude crimen falsi.

The court the judgment of conviction.

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