Case brief summary
A judge can refuse to admit evidence if its ability to unfairly sway the jury is much greater than its usefulness in proving a fact, under a rule called Federal Rule of Evidence 403.
Facts
Old Chief was charged with illegally possessing a gun as a felon, and he offered to admit he had a qualifying prior felony so the jury would not hear that the earlier crime was an assault causing serious injury.
Procedural history
The trial court let the prosecution introduce the full record of the prior conviction over Old Chief's objection, he was convicted, and the Court of Appeals for the Ninth Circuit affirmed that ruling.
Issue
Does a trial judge wrongly use their discretion by refusing a defendant's offer to admit a prior felony and instead letting the jury hear the specific name and nature of that old crime?
Holding
Yes, when the only reason for the evidence is to prove the defendant was previously convicted of a qualifying crime, the judge must accept the admission instead of letting in the full record naming the crime.
Reasoning
Naming the exact past crime barely helps prove the current charge, since only the general category matters legally. But it risks making jurors judge the defendant as a bad person instead of weighing the actual evidence.
Opinions
Majority (Souter): The judge should have accepted Old Chief's offer to admit his prior felony because naming the specific old crime risked unfair prejudice without adding real proof value.
Dissent (O'Connor): The government should be allowed to prove every element of its case with evidence of its choosing, and naming the prior crime was not unfairly prejudicial or unconstitutional.