Federal 7th Circuit Court
Criminal Court
Evidence
In prosecution on armed robbery charge, Dist. Ct. did not err in
admitting evidence of uncharged fraudulent check-cashing scheme where
such evidence was admissible under Rule 404(b) to explain ongoing
criminal relationship between defendant and others that led to their
participation in charged offense. Fact that check-cashing scheme had
little similarity to charged offense was immaterial. Moreover, Dist. Ct.
did not err in admitting officer's statement regarding third-party's
out-of-court identification of defendant as culprit where defendant was
given opportunity to recall third-party to witness stand to discuss said
identification.