U.S. v. Miller

In prosecution on drug distribution and firearms charges, defendant was entitled to new trial on drug distribution charges where Dist. Ct. erred in admitting defendant's 2000 conviction on drug distribution charge since defendant's prior conviction constituted improper propensity evidence. While prior conviction could be admitted under different circumstances to establish defendant's intent, instant evidence was improper where defendant contended that drugs contained in priced packets found in his residence were not his, and where govt. failed to explain how defendant's 2000 conviction related to his intent or any other relevant issue without resorting to improper propensity evidence.