Huddleston v. U.S.

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Huddleston v. U.S.
Date decided


Huddleston was on trial for selling stolen goods. Prosecution wanted to offer evidence of him selling other stolen goods in the past.


Is evidence of Defendant's previous crimes relevant?


No, the evidence has low probative value and unfair prejudice so does not pass Rule 403.


Analytical process:

  • 401/402? (are the past incidents of stealing relevant?): Yes
  • 404
    • Potential 404 problem: P is trying to go right through the propensity box (i.e., he’s just the type of guy who steals stuff)
    • D argues he didn’t know goods are stolen as crux of his defense. So, Prosecution argues that the stolen TVs put Huddleston on notice so he should have known things he sold after were stolen (though it’s not factually clear if the TVs were actually stolen)
      • i.e., you can’t be put on notice before you learned TVs were stolen
  • 403: Even if the last act gets past 404, it has low PV and high UP and fails 403
    • This shows us what to do when it’s sort of unclear whether the guy actually did the thing that’s being introduced as 404(b) past-act, non-propensity evidence
      • i.e., if trying to bring in other acts for another purpose (knowledge/motive), how convinced do we need to be that those acts actually happened?
    • Standard: Judge determines if a reasonable jury would find by a preponderance of evidence that the facts in question are true.