Huddleston v. United States

Huddleston was being tried for selling stolen goods and possessing stolen goods, related to two portions of a shipment of Memorex 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 into their decisions.

Chief Justice Rehnquist wrote for the unanimous court. 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: 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, having heard of the similar act, it believed him to be an evil person, and thus might convict him for something other than the crime for which he was charged. This danger is unfair prejudice. Because unfair 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, and all evidence against a defendant is prejudicial against the defendant, but the evidence is inadmissible if the danger of unfair prejudice substantially outweighs its probative value. The other rules, including the rule about similar acts evidence, are 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 unfair prejudice that might result from admitting similar acts evidence.

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 Association has proposed to amend FRE 404 to require that prior offenses be proven by a clear and convincing standard.[1] Prior to the Court's decision, Edward Imwinkelried had proposed that prosecutors should be burdened to show that admitting the prior offense would be more probative than prejudicial.[2]

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• Text of Huddleston v. United States, 485 U.S. 681 (1988) is available from:  CourtListener  Findlaw  Google Scholar  Justia  Library of Congress  Oyez (oral argument audio) 
• Case brief