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A prior conviction may be sufficiently probative of something material, even though dissimilar, when it makes the existence of the defendant's knowledge more probable than it would be without the evidence.
Defendant Martinez and Serrano smuggled methamphetamine into the United States. Their courier, Crystal York, got caught in the airport. She agreed to help the police catch her boyfriend, Serrano, and the person to whom he was delivering the methamphetamine, Martinez. Serrano went inside the terminal and was arrested. Martinez was detained, and when Crystal identified Martinez to the police as a man to whom Serrano had previously delivered drugs, he was arrested. During trial, defendant Martinez’s previous conviction was allowed as evidence; however, the trial judge admonished the jury that it could not infer guilt from the prior conviction, but only use the evidence insofar as it bore on knowledge, intent, and so forth. Defendant was convicted. On appeal, defendant argued that the judge erred by allowing in evidence of a prior conviction for importing heroin, since the same was not relevant to anything permitted to be proved under Federal Rule of Evidence 404(b).
Did the trial court err in allowing defendant’s prior conviction for importing heroin as evidence in defendant’s current criminal case?
The court affirmed the conviction and sentence. According to the court, the trial judge carefully considered the evidence of defendant's prior conviction for a drug offense, and admonished the jury that it could not infer guilt from the prior conviction, but only use the evidence insofar as it bore on knowledge, intent, and so forth. Though the prior offenses were for different drugs, the fact that distribution quantities were involved made the crimes similar enough to bear on defendant's knowledge. The judge carefully considered the risk of unfair prejudice, but reasonably concluded that it was outweighed by the probative value of the evidence. There was a logical connection between the knowledge that would have been gained from the prior crime and the knowledge at issue in defendant's case.