Source: cases/18usc922/us-519-172-old-chief-v-us.case
Case source: https://www.neochart.com/catalog/cases/us/volume_519/0172_01/index.html
Congress, however, has made it plain that distinctions among generic felonies do not count for this purpose; the fact of the qualifying conviction is alone what matters under the statute.
The statutory language in which the prior-conviction requirement is couched shows no congressional concern with the specific name or nature of the prior offense beyond what is necessary to place it within the broad category of qualifying felonies
In this ease, as in any other in which the prior conviction is for an offense likely to support conviction on some improper ground, the only reasonable conclusion was that the risk of unfair prejudice did substantially outweigh the discounted probative value of the record of conviction, and it was an abuse of discretion to admit the record when an admission was available.
casedsl 1 case /us/519/0172-01 name Old Chief v. United States cite 519 U.S. 172 (1997) court Supreme Court of the United States date 1997-01-07 url catalog/cases/us/volume_519/0172_01/index.html source ir/caselaw/us_519.jsonl sha1=eb81a95c0d2456394c96f6e4dcbe01a4cf2248fd chars=57254 law 18usc922 (g)(1) role rule-announced posture criminal; jury conviction on 922(g)(1) and assault/924(c) counts after the district court let the Government refuse a stipulation and admit the full record of the prior conviction; CA9 affirmed; certiorari on Fed. R. Evid. 403 result remanded element status.g1 : not-reached scope procedural variant proof-of-prior-conviction/defendant-offers-to-stipulate-felon-status fact @1768..1872 [supports] | The earlier crime charged in the indictment against Old Chief was assault causing serious bodily injury. fact @2590..2790 [supports] | he offered to “solve the problem here by stipulating, agreeing and requesting the Court to instruct the jury that he has been convicted of a crime punishable by imprisonment exceeding one (1) yea[r].” fact @3901..4031 [supports] | At trial, over renewed objection, the Government introduced the order of judgment and commitment for Old Chief’s prior conviction. rule @27697..27884 | Congress, however, has made it plain that distinctions among generic felonies do not count for this purpose; the fact of the qualifying conviction is alone what matters under the statute. rule @19619..19865 | The statutory language in which the prior-conviction requirement is couched shows no congressional concern with the specific name or nature of the prior offense beyond what is necessary to place it within the broad category of qualifying felonies held @29620..29994 | In this ease, as in any other in which the prior conviction is for an offense likely to support conviction on some improper ground, the only reasonable conclusion was that the risk of unfair prejudice did substantially outweigh the discounted probative value of the record of conviction, and it was an abuse of discretion to admit the record when an admission was available. gloss Evidence ruling, not a ruling on whether the status element was met (it was never disputed: the defendant offered to admit it). What the opinion says about the element: only the fact of a qualifying conviction matters, not the name or nature of the offense, and status is independent of the events of the charged possession; hence a defendant's offer to admit felon status makes the full record of conviction excludable under Rule 403 when its only purpose is to prove status. Harmless error left for remand. element possession : not-reached gloss Arrest after a fracas involving at least one gunshot; the jury convicted; possession is not reviewed. misfit The opinion is essentially a Fed. R. Evid. 403 decision; no declared id covers an evidentiary ruling. It is recorded under status.g1 with role rule-announced + scope procedural because the Court's reasoning depends on a characterisation of that element (status, generic, outside the narrative of the offense), but the `held` line is a holding about admissibility, not about the element. misfit The jury's guilty verdict (status proved by the judgment record) could be a lower-court `satisfied [proved]` block, but the conviction's validity is exactly what is left open on remand (harmless error), and no scope means "found below, verdict possibly tainted"; not recorded. misfit Fact polarity is nominal: all three facts tend to show the conviction existed; the real dispute (prejudice from disclosing the name of the offense) has no polarity relative to the element. misfit `result remanded` hides that the defendant won the only question decided. O'Connor, J. (with Rehnquist, C.J., Scalia and Thomas, JJ.) dissented; only its opening was read; not recorded.