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The court of appeals reviews decisions regarding the admissibility of evidence under an abuse of discretion standard. In balancing the prejudicial effect and probative value, great deference is given to the district judge's determination. In addition, Fed. R. Evid. 404(b) is a rule of inclusion rather than exclusion and admits evidence of other crimes or acts relevant to any issue in the trial, unless it tends to prove only criminal disposition.
The defendant, Ronald Claxton, appealed his convictions for possession of a firearm by a convicted felon in violation of 18 U.S.C. § 922(g)(1) and for possession of an unregistered, sawed-off shotgun in violation of 26 U.S.C. § 5861. On appeal, Claxton contended that: (1) the admission of evidence regarding narcotics trafficking was an abuse of discretion and (2) refusal of the proffered theory of defense instruction was in error.
Did the district court abuse its discretion in its admission of evidence regarding narcotics trafficking?
The reviewing court concluded that the district court did not abuse its discretion in admitting the evidence regarding the drugs found in the apartment. The drug evidence was properly admitted for the purpose of showing Claxton’s motive for possessing the guns and was relevant to the issue of the ownership. Although he later recanted the statements, Claxton had initially admitted to ownership of the guns, his possession of the guns for self-protection, and his involvement with the sale of drugs and the trading of drugs for other goods found in the apartment. As for the proffered instruction, although it was timely submitted, contained a correct statement of the law, and was supported by the evidence, the refusal to give it did not abuse the broad discretion accorded to the district court in framing the instructions given.