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Old Chief v. United States

Supreme Court of the United States

October 16, 1996, Argued ; January 7, 1997, Decided

No. 95-6556.

Case Summary

Procedural Posture

The U.S. Court of Appeals for the Ninth Circuit affirmed defendant's conviction for assault with a deadly weapon, using a firearm in relation to a crime of violence, and possession of a firearm by a convicted felon, holding that the district court did not abuse its discretion by allowing the prosecution to introduce evidence of defendant's prior conviction. Defendant sought a writ of certiorari.

Overview

The charges against defendant resulted from a fracas involving at least one gunshot. Before trial, defendant moved for an order prohibiting the government from mentioning or offering into evidence any testimony regarding his prior criminal conviction for assault causing serious bodily injury, except to state that he had been convicted of a crime punishable by imprisonment exceeding one year. Defendant also offered to stipulate that he had been convicted of such a crime. The government refused the offered stipulation, and the district court ruled that the government was not required to so stipulate. The government introduced at trial, over defendant's objection, the order of judgment and commitment for defendant's prior conviction. The jury found defendant guilty on all counts, and the appellate court affirmed. On certiorari review, defendant argued that his offer to stipulate rendered the prior conviction inadmissible under Fed. R. Evid. 403. The Court agreed, holding that the district court abused its discretion in admitting defendant's record of conviction because its discounted probative value was substantially outweighed by the risk of unfair prejudice.

Outcome

The Court reversed the appellate court's judgment and remanded for further proceedings.

LexisNexis® Headnotes

 

 

Criminal Law & Procedure > ... > Possession of Weapons > Unregistered Firearm > Elements

Criminal Law & Procedure > ... > Weapons Offenses > Possession of Weapons > General Overview

Criminal Law & Procedure > ... > Standards of Review > Abuse of Discretion > General Overview

Criminal Law & Procedure > ... > Standards of Review > Abuse of Discretion > Evidence

HN1  Unregistered Firearm, Elements

Subject to certain limitations, 18 U.S.C.S. § 922(g)(1) prohibits possession of a firearm by anyone with a prior felony conviction, which the government can prove by introducing a record of judgment or similar evidence identifying the previous offense.

 

Criminal Law & Procedure > ... > Standards of Review > Abuse of Discretion > Evidence

Evidence > Relevance > Preservation of Relevant Evidence > Exclusion & Preservation by Prosecutors

Criminal Law & Procedure > ... > Standards of Review > Abuse of Discretion > General Overview

HN2  Abuse of Discretion, Evidence

The standard of review applicable to the evidentiary rulings of a district court is abuse of discretion.

 

Criminal Law & Procedure > ... > Use of Weapons > Commission of Another Crime > Elements

Criminal Law & Procedure > Criminal Offenses > Weapons Offenses > General Overview

Criminal Law & Procedure > ... > Weapons Offenses > Possession of Weapons > General Overview

HN3  Commission of Another Crime, Elements

See 18 U.S.C.S. § 922(g)(1).

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519 U.S. 172 ; 117 S. Ct. 644 ; 136 L. Ed. 2d 574 ; 1997 U.S. LEXIS 298 ; 65 U.S.L.W. 4049; 45 Fed. R. Evid. Serv. (Callaghan) 835; 97 Fulton County D. Rep. 174; 97 Cal. Daily Op. Service 177; 97 Daily Journal DAR 277; 10 Fla. L. Weekly Fed. S 238

JOHNNY LYNN OLD CHIEF, PETITIONER v. UNITED STATES

Prior History:  [1]  ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.

Disposition: 56 F.3d 75, reversed and remanded.