OLD CHIEF V. UNITED STATES
519 U.S. 172 (1997)
NATURE OF THE CASE: This was a dispute over admission of an old conviction under a trial
for violation of 18 U.S.C. 922 (g)(1).
FACTS: D was charged with possession of a firearm in violation of 18 U.S.C. 922 (g)(1)
which prohibits possession of a firearm by anyone with a prior felony conviction. Part of
the State's case was the introduction of the prior felony conviction and D offered a
stipulation to that conviction but wanted to keep out the exact nature of the prior
conviction. D said that revealing the name and nature of his prior assault conviction would
unfairly tax the jury's capacity to hold P to its burden of proof beyond a reasonable doubt
on current charges. D argued that the offer to stipulate to the fact of the prior conviction
rendered evidence of the name and nature of the offense inadmissible under Rule 403 the
danger being that unfair prejudice from that evidence would substantially outweigh its
probative value. The State refused to join the stipulation and the conviction and all its
details were entered into evidence. D was convicted and appealed. The Ninth Circuit
addressed the point with brevity: Regardless of the defendant's offer to stipulate, the
government is entitled to prove a prior felony offense through introduction of probative
evidence. Under Ninth Circuit law, a stipulation is not proof, and, thus, it has no place in
the FRE 403 balancing process. The Ninth circuit affirmed. The Supreme Court granted
certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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