United States v. Riddle - 103 F.3d 423 (5th Cir. 1997)

Rule:

Unduly prejudicial extraneous evidence often plays on the jury's emotions unfairly, but prejudice can result from any of the significant factors set out in Fed. R. Evid. 403, of which inflamed passion is only one. These other factors include confusion of the issues and misleading the jury, and they are especially troubling when they take up a significant portion of the government's case.

Facts:

Defendant had numerous financial interests, including control of at least two lending institutions. He used his authority to obtain loans from the institutions to his business partners and himself. Upon default, he was charged with bank fraud, misapplication of bank funds, making false entries, and conspiracy. At trial, the district court allowed the government to present lay testimony from a bank and disallowed the defense expert because his testimony consisted of largely legal conclusions. Further, the district court admitted highly prejudicial documents and testimony showing criminal intent as well as documents dealing with unrelated loan transactions. Defendant was convicted. Defendant appealed. 

Issue:

Did the district court err in admitting prejudicial documents and testimony, thereby warranting the reversal of defendant’s conviction? 

Answer:

Yes.

Conclusion:

The court reversed, holding that the cumulative effect of the errors produced an unfair trial. The court noted that the inspector's testimony went beyond the latitude allowed to lay witnesses with specialized knowledge and the loss of the defense expert handicapped the effort to explain how banks operate. In addition, the remaining evidence was admitted to show motive, but the probative value was slight while the resulting effect was highly prejudicial.