Law School Case Brief
Gov't of the V.I. v. Archibald - 987 F.2d 180 (3d Cir. 1993)
The court of appeals exercises great restraint in reviewing a district court's ruling on the admissibility of evidence under Fed. R. Evid. 403. Where an objection does invoke Rule 403, the trial judge should record his balancing analysis to the extent that his exercise of discretion may be fairly reviewed on appeal. Where the trial judge fails to perform the required balancing and to explain the grounds for denying a Rule 403 objection, the court of appeals may undertake to examine the record, and the court of appeals need not defer to the reasoning of the district court.
Defendant Alan Archibald was convicted of aggravated rape in in federal district court. The alleged victim was L.C., who, at the time of the events in question, was 10 years of age and living with her aunt, Marlene Chinnery. In Oct. 1991, Marlene Chinnery noticed that the screen from L.C.'s bedroom window and several stones were lying on her bedroom floor. The aunt also found a long curtain rod and a piece of board outside L.C.'s bedroom window and stains on L.C.'s bedspread. When confronted by her mother, Ursula Williams, L.C. stated that she had engaged in sexual intercourse with Archibald. Williams testified that she knew Archibald because he was a neighbor and because he had fathered the child of her daughter, T.C. She further testified that, at the time of trial, T.C. was 15 years of age, and the child was six months old. Williams' testimony thus revealed that Archibald had engaged in sexual intercourse with Tasha when she was 13 or fourteen years old. At trial, Archibald objected, under Fed. R. Evid. 404(b), to Williams' testimony on the ground that evidence of his prior criminal act was inadmissible. The district court disregarded the objection, gave the jury a limiting instruction as requested by the Government and allowed the Government to continue examining Williams. Archibald appealed.
Did the district court commit reversible error by admitting evidence of prior criminal conduct and improper hearsay testimony?
On appeal, the court reversed Archibald's conviction and remanded for a new trial. The court noted that the evidence of Archibald's prior criminal act of engaging in sexual intercourse with the victim's sister, a minor, was a prior crime within the meaning of Fed. R. Evid. 404(b). Given that Archibald was on trial for having engaged in intercourse with a 10-year-old girl, it was highly likely the jury drew an adverse character inference that Archibald had intercourse with the victim's sister. Williams' mother's testimony revealing the prior sexual encounter between Archibald and the victim's sister was not probative of any material issue except Archibald's propensity to commit the charged crime. As a result, the evidence was inadmissible under Rule 404(b). The court also found that the admission of hearsay testimony was not harmless error because such testimony was the only evidence corroborating Archibald's alleged sexual attraction to the victim.
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