U.S. v. Powell

In prosecution on two counts of drug distribution charge, Dist. Ct. erred in admitting evidence of defendant's participation in other, uncharged drug transactions in violation of Rule 404(b) where basis of admission was claim that said evidence was admissible to establish defendant's intent to unlawfully distribute drugs at issue in charged offense. Instant drug distribution charge was only general intent crime, and defendant never placed his intent at issue in instant case, such that admission of other bad acts was probative only of defendant's propensity to commit crimes. Error, though, was harmless given various recordings of each controlled purchase, and given defendant's telephone call admitting his role in said purchases.