U.S. v. Chapman

Federal 7th Circuit Court
Criminal Court
Evidence
Citation
Case Number: 
No. 12-1415
Decision Date: 
August 28, 2014
Federal District: 
N.D. Ill., E. Div.
Holding: 
Vacated and remanded
In prosecution on drug distribution and unlawful possession of firearms charges, Dist. Ct. erred in admitting under Rule 404(b)(1) details of defendant’s prior heroin-trafficking conviction, even though govt. argued that said evidence was relevant as to issue of defendant’s knowledge of drugs and intent to commit charged offenses, since relevance of defendant’s prior conviction depended on forbidden propensity evidence and its probative value was substantially outweighed by risk of unfair prejudice, where defendant’s only defense was that he did not possess either drugs or firearm. Dist. Ct. also erred in precluding defendant from testifying that he pleaded guilty to all six prior felony convictions that had been admitted into evidence on issue of defendant’s credibility, where Dist. Ct. was under misimpression that Rule 609 categorically precluded defendant from admitting proposed evidence.