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United States v. Carroll - 207 F.3d 465 (8th Cir. 2000)

Rule:

In order to admit Fed. R. Evid. 404(b) identity evidence on the signature facts or modus operandi theory, the district court must make a threshold determination that, based solely on the evidence comparing the past acts and the charged offense, a reasonable juror could conclude that the same person committed both crimes. Two factors are relevant in analyzing the question. The first is the distinctiveness of the facts that make the crimes unique and the second is the proximity of the crimes in space and time.

Facts:

In feral district court, defendant Gerald Carroll was convicted by a jury of armed robbery of a federally insured credit union and a related firearms charge. He was sentenced by the district court to life in prison plus 20 years. Carroll appealed, arguing that evidence of a 10-year-old prior conviction for armed robbery was improperly admitted into evidence at trial; that certain post-arrest statements were wrongly introduced into evidence, and; that 18 U.S.C.S. § 3559(c), the so-called "three strikes" law, which required his lengthy sentence, was unconstitutional.

Issue:

Was Carroll's prior conviction erroneously admitted into evidence at trial?

Answer:

Yes.

Conclusion:

The court of appeals affirmed Carroll's conviction and sentence. The court found that Carroll's prior conviction was erroneously admitted, but that such error was harmless. The court concluded that based on the generic nature of the crimes and on the 10 years that passed between them, the prior conviction was not relevant to prove identity through modus operandi because no substantial inference of identity reasonably could be made. However, the court ruled, given the "overwhelming" evidence against Carroll, the admission of evidence of Carroll's prior conviction had only a slight impact on the trial, and thus the error was harmless. The court further ruled that although the police used force against Carroll during his arrest, there was no evidence in the record to suggest that Carroll answered an arresting officer's question as to the whereabouts of Carroll's gun because he feared the police would use further force against him. Thus, Carroll's statement was properly admitted. Finally, the court ruled, based on long-standing precedent, § 3559(c) was not unconstitutional.

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