Nicholas Craig Woozencroft v. United States
Whether evidence can satisfy Rule 401's relevance standard in criminal jury trials even if the evidence would not tend to disprove every alternative theory of guilt?
Generally, relevant evidence is admissible at trial. Evidence is relevant —in civil and criminal cases alike —if “it has any tendency to make a fact more or less probable than it would be without the evidence,” and “ the fact is of consequence in determining the action. ” Fed. R. Evid. 401. See also Fed. R. Evid. 1101(a) -(b). Under Seventh Circuit precedent, evidence need not tend to disprove every claim within an action to satisfy Rule 401. But that appears to be precisely what the Eleventh Circuit’s decision below requires, particularly where a jury is presented with alternative theories of a crime. The petitioner therefore asks whether evidence can satisfy Rule 401’s relevance standard in crim inal jury trials even if the evidence would not tend to disprove every alternative theory of guilt?