United States v. Copelin case brief

United States v. Copelin case brief summary
996 F.2d 379 (D.C. Cir. 1993)

CASE SYNOPSIS

Appellant-defendant sought review of judgment of the United States District Court for the District of Columbia, convicting him on one count of unlawful distribution of cocaine.

CASE FACTS
Defendant was convicted of unlawful distribution of cocaine. At trial he was cross-examined by the prosecution concerning his three positive drug tests for cocaine while on pre-trial release. The court admitted the evidence without issuing an immediate limiting instruction to the jury. Defendant appealed, arguing that the trial court committed reversible error by not excluding the evidence in the first instance, and alternatively by not issuing an immediate limiting instruction.

DISCUSSION

• The appellate court ruled that the district court's decision to admit the evidence regarding the positive drug tests was proper because it was admitted as impeachment evidence. 
• However, the court ruled that failure to issue an immediate cautionary instruction informing the jury as to the permissible uses of the evidence constituted plain error because such evidence could substantially prejudice the defendant if misused by the jury. 
• The court therefore reversed the conviction and remanded for a new trial.

CONCLUSION
The court reversed the conviction and remanded for a new trial, holding that although admission of evidence regarding positive drug tests was proper as impeachment evidence, its prejudicial nature required the court to issue an immediate cautionary instruction informing the jury as to permissible uses of such evidence.

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