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United States v. Jackson - 368 F.3d 59 (2d Cir. 2004)

Rule:

It is common knowledge that in many instances men bear identical names and that evidence, without more, is not sufficient to prove a defendant's prior conviction.

Facts:

The defendant, Aaron Jackson, was found guilty after a two-day trial in 2001. Special Agent Matthew White of the United States Bureau of Alcohol, Tobacco and Firearms (ATF) was the principal government witness. He testified that, in carrying out his duties, which included investigating illegal possession of firearms by convicted felons, he and other agents of the ATF went on September 7, 1999 to Jackson's apartment in the Bronx and asked him whether he had any firearms or ammunition, whereupon Jackson showed them a safe containing a quantity of ammunition. The agents seized the ammunition. To prove that Jackson was a previously convicted felon, the government offered a certified copy of a judgment of the New York Supreme Court for New York County (Manhattan) showing that on January 11, 1984, a person named Aaron Jackson was convicted of unlawful possession of a weapon and of a controlled substance. The government offered no further evidence connecting defendant to the 1984 conviction. Defendant neither testified nor called witnesses in his defense. On summation, defense counsel argued for the first time that the government had failed to prove that the Aaron Jackson named in the certificate of conviction might be someone other than the defendant on trial. The jury found defendant guilty. Defendant challenged the legal sufficiency of the trial evidence offered to prove that, at the time he possessed ammunition, he had a prior felony conviction. The government argued that a conviction record in defendant's name was sufficient if defendant offered no contrary evidence.

Issue:

Was a conviction record in defendant’s name sufficient to prove that the defendant had prior felony conviction?

Answer:

No.

Conclusion:

The appellate court held that it could not accept the United States' arguments. According to the Court of Appeals for the Second Circuit, a court record that showed a conviction of a similarly named person (especially an 18-year-old record) could not conceivably furnish assurance beyond a reasonable doubt that it pertained to the present defendant. The court rejected the United States' proposed rule that sufficiency was satisfied as the result of defendant's failure to offer proof in rebuttal. The appellate court concluded that the corroborating evidence was scant and inconsistent; thereby, it reversed the district court’s decision.

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