U.S. v. Del Valle

In prosecution on mail fraud charges stemming from scheme to award City of Chicago jobs to individuals who participated in campaign work, Dist. Ct. did not commit reversible error by initially allowing prosecutor to ask defendant about DUI incident and incident in which defendant argued with police officer as passenger in car, and then shortly thereafter instructing jury to disregard said evidence, which Dist. Ct. mischaracterized as two incidents of "drunk driving." Evidence of defendant's guilt was overwhelming so as to preclude defendant from establishing any prejudice, and defendant was permitted to give context to said incidents on re-direct. Moreover, it was unlikely Dist. Ct.'s mischaracterization of evidence that was subject of limiting instruction precluded jury from following remaining portion of instruction to disregard type of evidence that was subject of limiting instruction.