Federal 7th Circuit Court
Criminal Court
Evidence
In prosecution on charge of unlawful distribution of cocaine-base, Dist. Ct. did not err in admitting evidence of defendant's 2005 conviction for possession with intent to distribute crack cocaine, even though defendant argued that said evidence only established his propensity to commit drug crimes. Said conviction was admissible to prove intent to distribute (even though defendant denied possession of said drugs) and to rebut defendant's claim that he had only used, but not sold drugs. Moreover, while Dist. Ct. erred in admitting portions of defendant's IDOC printout of his prior convictions, where some of listed convictions did not qualify as predicate offenses to establish career offender status, any error was harmless where instant conviction was based on video and audio evidence of certain controlled purchases involving defendant.