Supreme Court of the United States · 1997-01-07
18usc922: author: Fable · not independently reviewed
Case and law context
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; claim: (g)(1)
Uncertainty
None recorded
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.
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.
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.
`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.
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 12
| Case | One applicable prohibited category | Section 925(a)(1) government-use firearm or ammunition exception | Actual or constructive possession | Firearm or ammunition under section 921 | Possession in or affecting commerce | Knowledge of possessing the firearm or ammunition |
|---|---|---|---|---|---|---|
| Old Chief v. United States — 519 U.S. 172 (1997) · Supreme Court of the United States · 1997 (18usc922: author: Fable · not independently reviewed) | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: rule-announced/merits | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 12
| Case | Knowledge of the relevant disqualifying status | Second Amendment limit on the unlawful-user theory applied to Hemani | Ship or transport in interstate or foreign commerce | Knowing shipping, transportation or receipt | Receipt of the prohibited object | Received object previously shipped or transported across borders |
|---|---|---|---|---|---|---|
| Old Chief v. United States — 519 U.S. 172 (1997) · Supreme Court of the United States · 1997 (18usc922: author: Fable · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Old Chief v. United States — 519 U.S. 172 (1997) · Supreme Court of the United States · 1997 — not reached (18usc922: author: Fable · not independently reviewed) | Actual or constructive possession | not_reached Excluded from merits counts rule-announced / merits claim: (g)(1) Arrest after a fracas involving at least one gunshot; the jury convicted; possession is not reviewed. | Unspecified route | No source quotation recorded for this block. |
| Old Chief v. United States — 519 U.S. 172 (1997) · Supreme Court of the United States · 1997 — not reached (18usc922: author: Fable · not independently reviewed) | Conviction punishable by more than one year | not_reached Excluded from merits counts rule-announced / procedural claim: (g)(1) 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. | defendant-offers-to-stipulate-felon-status | The earlier crime charged in the indictment against Old Chief was assault causing serious bodily injury.Source: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [1768:1872] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8.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].”Source: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [2590:2790] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8.At trial, over renewed objection, the Government introduced the order of judgment and commitment for Old Chief’s prior conviction.Source: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [3901:4031] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8.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.Source: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [27697:27884] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8.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 feloniesSource: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [19619:19865] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8.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.Source: docroot/ir/caselaw/us_519.jsonl#/us/519/0172-01; Unicode character offsets [29620:29994] (end exclusive); SHA-256 c1dc51cfade98e51de456f71dd24d2a52253aa52d339b0d1d35df3ef3be561a8. |