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Law School Case Brief

United States v. Woods - 484 F.2d 127 (4th Cir. 1973)

Rule:

Evidence of other offenses may be received, if relevant, for any purpose other than to show a mere propensity or disposition on the part of the defendant to commit the crime, provided that the trial judge may exclude the evidence if its probative value is outweighed by the risk that its admission will create a substantial danger of undue prejudice to the accused.

Facts:

Defendant was convicted of murder. On appeal, he asserted that the government failed to prove beyond a reasonable doubt the corpus delicti of murder and that, even if evidence of prior acts was admissible to prove the corpus delicti, the evidence in this case was inadmissible because it was too insubstantial. Defendant also contended that even if the evidence of prior acts was otherwise admissible, the jury was improperly instructed by the district court with regard to the consideration it might give to such evidence.

Issue:

Is the evidence of prior crimes of the defendant admissible as evidence in defendant’s murder conviction?

Answer:

Yes.

Conclusion:

The court affirmed defendant's convictions, holding that, unlike other cases where evidence of prior crimes was admissible for only limited purposes and where it was necessary or proper to give limiting instructions, evidence of prior events was admissible to prove both the victim of an infanticide and that defendant was the perpetrator of the crime.

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