U.S. v. Edwards

Dist. Ct. did not err in admitting evidence regarding defendant’s involvement in robbery of two cell-phone stores (to which defendant had pleaded guilty) in attempt to establish defendant’s modus operandi with respect to charged third cell-phone store robbery to which defendant had not pleaded guilty. Although defendant argued that admission of said evidence constituted improper propensity evidence, Dist. Ct. could properly find that said evidence was properly admitted to show identity through modus operandi, where all three robberies showed sufficient commonalities with respect to pattern of conduct when robbing stores, similarities in clothing, similar theft of items and similar retreats from store after robbery. Moreover, facts from each robbery closely resembled each other, which reduced risk that evidence of robberies to which defendant had pleaded guilty would be inflammatory. Also, Dist. Ct. provided appropriate limiting instructions that mitigated any potential for unfair prejudice.