U.S. v. Lee

In prosecution on charge of conspiracy to distribute cocaine base, Dist. Ct. abused its discretion in admitting evidence of defendant’s 2004 conviction on charge of possession of cocaine base, even though govt. contended that defendant’s prior conviction was probative of defendant’s knowledge, intent and absence of mistake. Issues regarding defendant knowledge, intent and absence of mistake were not relevant where defendant claimed that he had no knowledge of cocaine base found in his car, such that introduction of his prior conviction improperly suggested to jury that defendant had propensity to commit charged offense. Moreover, error required new trial, even though there was sufficient evidence to support defendant’s conviction, including fact that defendant’s latent fingerprint was on packet of cocaine base, since introduction of defendant’s prior conviction invited jury to decide defendant’s guilt for wrong reason.