Huddleston v. United States
Encyclopedia
Huddleston v. United States, 485 U.S. 681
(1988), was a case in which the United States Supreme Court
removed a procedural obstacle to admitting evidence of a witness's motive, plan, or knowledge that had been imposed by some courts of appeals after reading Rule 104(b) of the Federal Rules of Evidence
. The court reaffirmed that there are adequate other mechanisms present in the Rules to ensure that overly prejudicial evidence does not reach the jury.
videocassettes that had been stolen from the Overnight Express yard in South Holland, Illinois
. Huddleston later sold the missing videocassettes to the owner of Magic Rent-to-Own in Ypsilanti, Michigan
. At the trial, he did not dispute that the cassettes had been stolen. He contested a crucial element of the charged crimes — whether he knew that the cassettes had been stolen.
To prove this element, the government sought to introduce two pieces of "similar acts" evidence that was relevant to Huddleston's knowledge that the videocassettes were stolen. First, the government called Paul Toney, a record store owner, to testify that Huddleston had offered to sell him some 12" black-and-white television
sets for $28 each. Toney testified that Huddleston told him he could obtain several thousand of these televisions. Toney eventually accompanied Huddleston to the Magic Rent-to-Own store on two occasions, and bought a total of 38 televisions.
Second, the government called Robert Nelson, an undercover FBI agent posing as an appliance dealer, to testify that Huddleston had offered to sell him a large quantity of Amana
appliances. Nelson agreed to pay $8,000 for the appliances. At the time appointed to make the delivery, Nelson arrested Huddleston, and found that he had brought part of a shipment of appliances that had been stolen.
Huddleston testified at the trial that he had obtained the videocassettes legitimately. The prosecution explained in closing arguments that Huddleston was being tried only for the videocassettes, and that the evidence about the televisions and the appliances was intended to help the jury determine whether Huddleston knew that the videotapes had been stolen. The jury convicted Huddleston on the possession charge but not on the sale charge.
Huddleston appealed his conviction to the Sixth Circuit
. That court initially reversed the conviction because the government had not proven by clear and convincing evidence that Huddleston had known that either the televisions or the appliances had been stolen, and thus that those incidents were not admissible against Huddleston in his trial on the videocassette charges. After the Sixth Circuit decided in a different case that courts should prove similar acts evidence by a preponderance of the evidence, it upheld Huddleston's conviction because it concluded that the evidence regarding the televisions had been proven by a preponderance of the evidence.
The Supreme Court agreed to hear the case to decide whether courts should decide if similar acts evidence has been proven before allowing juries to factor it in to their decisions.
wrote for the majority. Frequently, in a trial, it is necessary to establish the truth of certain disputed issues by drawing inferences from a person's conduct. For example, in this case, Huddleston was on trial for selling stolen property, and the other acts to which Toney and Nelson had testified were similar to the one that Huddleston was accused of committing in this case. The law needs a mechanism to allow the jury to infer that if Huddleston knew in other similar circumstances that the goods in question were stolen, then it is more likely that on this occasion he knew the videocassettes were stolen. The danger associated with presenting this other act evidence is that the jury will convict the defendant because of his past actions, not because of his actions in this case.
The balance struck by Rule 404 of the Federal Rules of Evidence is this: Evidence of a person's prior actions that might adversely reflect on the actor's character is generally forbidden, but evidence that might relate to a relevant issue in the case, such as motive, opportunity, or knowledge, is admissible. In this case, the evidence that Huddleston knew that the televisions were stolen was probative of whether he knew that the videocassettes were stolen. Thus, it was properly admitted.
Huddleston argued that the mere fact that the evidence was probative was not sufficient to protect him from the danger that the jury might convict him because of the similar act or because it believed him to be an evil person having heard of the similar act. This danger is called prejudice. Because prejudice might result from introducing similar acts evidence, Huddleston argued that the Rules should require the judge to determine that the similar acts evidence was more likely than not true. The Court rejected this argument as inconsistent with the text and structure of the rules.
The rules on admissibility of evidence are meant to be the only standards for admitting evidence. All relevant evidence is admissible, unless the danger of prejudice outweighs its probative value. The other rules, including the rule about similar acts evidence, is intended to limit the purpose for which otherwise probative evidence may be admitted. The text of these rules does not require any other preliminary showing before admitting the evidence. Congress did not intend to superimpose another level of judicial oversight onto the admissibility rules; rather, it intended to ensure that no artificial barriers stood in the way of admitting probative evidence. The rules require the trial court to make threshold determinations on admissibility, including whether evidence is relevant, and whether it is not unfairly prejudicial. The court's power to make these determinations is sufficient to guard against the danger of prejudice that might result from admitting similar acts evidence.
has proposed to amend FRE 404 to require that prior offenses be proven by a clear and convincing standard. Edward Imwinkelried
has proposed that prosecutors should be burdened to show that admitting the prior offense would be more probative than prejudicial.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1988), was a case in which the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
removed a procedural obstacle to admitting evidence of a witness's motive, plan, or knowledge that had been imposed by some courts of appeals after reading Rule 104(b) of the Federal Rules of Evidence
Federal Rules of Evidence
The is a code of evidence law governing the admission of facts by which parties in the United States federal court system may prove their cases, both civil and criminal. The Rules were enacted in 1975, with subsequent amendments....
. The court reaffirmed that there are adequate other mechanisms present in the Rules to ensure that overly prejudicial evidence does not reach the jury.
Facts
Huddleston was being tried for selling stolen goods and possessing stolen goods, related to two portions of a shipment of MemorexMemorex
Memorex began as a computer tape producer and expanded to become a major IBM plug compatible peripheral supplier. It is now a consumer electronics brand of Imation specializing in disk recordable media for CD and DVD drives, flash memory, computer accessories and other electronics.Established in...
videocassettes that had been stolen from the Overnight Express yard in South Holland, Illinois
South Holland, Illinois
South Holland is a village in Cook County, Illinois, United States and serves as the seat of Thornton Township. The population was 22,147 at the 2000 census.-History:...
. Huddleston later sold the missing videocassettes to the owner of Magic Rent-to-Own in Ypsilanti, Michigan
Ypsilanti, Michigan
Ypsilanti is a city in Washtenaw County in the U.S. state of Michigan. As of the 2000 census, the city population was 22,362. The city is bounded to the north by the Charter Township of Superior and on the west, south, and east by the Charter Township of Ypsilanti...
. At the trial, he did not dispute that the cassettes had been stolen. He contested a crucial element of the charged crimes — whether he knew that the cassettes had been stolen.
To prove this element, the government sought to introduce two pieces of "similar acts" evidence that was relevant to Huddleston's knowledge that the videocassettes were stolen. First, the government called Paul Toney, a record store owner, to testify that Huddleston had offered to sell him some 12" black-and-white television
Television
Television is a telecommunication medium for transmitting and receiving moving images that can be monochrome or colored, with accompanying sound...
sets for $28 each. Toney testified that Huddleston told him he could obtain several thousand of these televisions. Toney eventually accompanied Huddleston to the Magic Rent-to-Own store on two occasions, and bought a total of 38 televisions.
Second, the government called Robert Nelson, an undercover FBI agent posing as an appliance dealer, to testify that Huddleston had offered to sell him a large quantity of Amana
Amana Corporation
The Amana Corporation is an American brand of household appliances. It was founded in 1934 by George Foerstner as The Electrical Equipment Co. in Middle Amana, Iowa to manufacture commercial walk-in coolers. The business was later owned by the Amana Society and became known as Amana Refrigeration,...
appliances. Nelson agreed to pay $8,000 for the appliances. At the time appointed to make the delivery, Nelson arrested Huddleston, and found that he had brought part of a shipment of appliances that had been stolen.
Huddleston testified at the trial that he had obtained the videocassettes legitimately. The prosecution explained in closing arguments that Huddleston was being tried only for the videocassettes, and that the evidence about the televisions and the appliances was intended to help the jury determine whether Huddleston knew that the videotapes had been stolen. The jury convicted Huddleston on the possession charge but not on the sale charge.
Huddleston appealed his conviction to the Sixth Circuit
United States Court of Appeals for the Sixth Circuit
The United States Court of Appeals for the Sixth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Kentucky* Western District of Kentucky...
. That court initially reversed the conviction because the government had not proven by clear and convincing evidence that Huddleston had known that either the televisions or the appliances had been stolen, and thus that those incidents were not admissible against Huddleston in his trial on the videocassette charges. After the Sixth Circuit decided in a different case that courts should prove similar acts evidence by a preponderance of the evidence, it upheld Huddleston's conviction because it concluded that the evidence regarding the televisions had been proven by a preponderance of the evidence.
The Supreme Court agreed to hear the case to decide whether courts should decide if similar acts evidence has been proven before allowing juries to factor it in to their decisions.
Decision of the Court
Chief Justice RehnquistWilliam Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
wrote for the majority. Frequently, in a trial, it is necessary to establish the truth of certain disputed issues by drawing inferences from a person's conduct. For example, in this case, Huddleston was on trial for selling stolen property, and the other acts to which Toney and Nelson had testified were similar to the one that Huddleston was accused of committing in this case. The law needs a mechanism to allow the jury to infer that if Huddleston knew in other similar circumstances that the goods in question were stolen, then it is more likely that on this occasion he knew the videocassettes were stolen. The danger associated with presenting this other act evidence is that the jury will convict the defendant because of his past actions, not because of his actions in this case.
The balance struck by Rule 404 of the Federal Rules of Evidence is this: Evidence of a person's prior actions that might adversely reflect on the actor's character is generally forbidden, but evidence that might relate to a relevant issue in the case, such as motive, opportunity, or knowledge, is admissible. In this case, the evidence that Huddleston knew that the televisions were stolen was probative of whether he knew that the videocassettes were stolen. Thus, it was properly admitted.
Huddleston argued that the mere fact that the evidence was probative was not sufficient to protect him from the danger that the jury might convict him because of the similar act or because it believed him to be an evil person having heard of the similar act. This danger is called prejudice. Because prejudice might result from introducing similar acts evidence, Huddleston argued that the Rules should require the judge to determine that the similar acts evidence was more likely than not true. The Court rejected this argument as inconsistent with the text and structure of the rules.
The rules on admissibility of evidence are meant to be the only standards for admitting evidence. All relevant evidence is admissible, unless the danger of prejudice outweighs its probative value. The other rules, including the rule about similar acts evidence, is intended to limit the purpose for which otherwise probative evidence may be admitted. The text of these rules does not require any other preliminary showing before admitting the evidence. Congress did not intend to superimpose another level of judicial oversight onto the admissibility rules; rather, it intended to ensure that no artificial barriers stood in the way of admitting probative evidence. The rules require the trial court to make threshold determinations on admissibility, including whether evidence is relevant, and whether it is not unfairly prejudicial. The court's power to make these determinations is sufficient to guard against the danger of prejudice that might result from admitting similar acts evidence.
Impact
Huddleston has been criticized for making it too easy for prosecutors to prove prior, unconvicted offenses for use under FRE 404(b). In response, the American Bar AssociationAmerican Bar Association
The American Bar Association , founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation...
has proposed to amend FRE 404 to require that prior offenses be proven by a clear and convincing standard. Edward Imwinkelried
Edward Imwinkelried
|birth_place =|death_date =|death_place =|nationality = United States|ethnicity =|fields = Evidence, Scientific Evidence|workplaces = University of California, Davis School of Law...
has proposed that prosecutors should be burdened to show that admitting the prior offense would be more probative than prejudicial.
See also
- List of United States Supreme Court cases, volume 485
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court