Supreme Court of the United States · 1997-01-07
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)
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Variant | Exact source quotations |
|---|---|---|---|---|
| /us/519/0172-01 — Supreme Court of the United States · 1997 | 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 variant | No source quotation recorded for this block. |
| /us/519/0172-01 — Supreme Court of the United States · 1997 | 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. | proof-of-prior-conviction/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. |