U.S. v. Reed

In prosecution on drug distribution and firearm charges, Dist. Ct. did not commit reversible error, when it admitted evidence regarding details of defendant’s prior drug distribution conviction, even though defendant argued that said evidence was relevant only to establish his propensity to commit charged offense. Dist. Ct. indicated that it used said evidence to establish similarity in packaging of drugs, and such evidence was questionable since it had only minimal probative value because subject packaging was not distinctive in drug industry. However, any error was harmless given substantial evidence connecting defendant to drugs and firearm found in his bedroom. Ct. noted though, that result might have been different had jury, as opposed to Dist. Ct. in instant bench trial, been trier of fact.