Steven Michael Cenephat v. United States
Privacy JusticiabilityDoctri
Does a court, in deciding whether a defendant's prior crime is relevant to the non-character issue of intent under Rule 404(b), need only determine whether the prior crime and the pending charge require proof of the same mental state?
Under Federal Rule of Evidence 404(b), evidence of someone’s prior crime “may be admissible” to prove a separately charged offense if the evidence “bears upon a relevant issue in the case.” Huddleston v. United States , 485 U.S. 681, 686 (1988); Fed. R. Evid. 404(b)(2). The rule, however, bars evidence “that might adversely reflect on th[at] [person’s] character.” Huddleston, 485 U.S. at 685. See also Fed. R. Evid. 404(b)(1). So the “threshold” question each court must decide before admitting prior crime evi dence under Rule 404(b) is “whether that evidence is probative of a material issue other than character.” Huddleston, 485 U.S. at 686. See also Fed. R. Evid. 404(b)(2). In the decision below, the Eleventh Circuit upheld the admission of the petitioner’s prior Florida felon -in-possession convictions, which the government had used to prove the intent element of a federal felon -in-possession charge. In so ruling, the Elevent h Circuit held that the prior convictions satisfied Rule 404(b)’s relevance requirement because the state of mind that needed to be proved to obtain the prior convictions and to convict on the federal charge matched . The question presented is as follows : Does a court, in deciding whether a defendant’s prior crime is relevant to the non-character issue of intent under Rule 404(b), need only determine whether the prior crime and the pending charge require proof of the same mental state?