U.S. v. Stevenson

In prosecution on drug conspiracy charge involving crack and cocaine sales, Dist. Ct. did not commit reversible error in admitting evidence of uncharged marijuana sales involving defendant, even though defendant argued that said evidence violated Rule 404(b) as evidence of uncharged “bad acts.” While govt. did not assert valid purpose for said evidence, any error was harmless given weight of evidence from others who testified that defendant supplied them with huge quantities of cocaine and that defendant actively participated in packing and transporting drugs and drug proceeds throughout conspiracy. Moreover, Ct. noted that marijuana evidence was essentially cumulative to evidence of defendant’s crack and cocaine sales.