Old Chief v. United States

519 U.S. 172 (1997)

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Nature of the Case

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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 the 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.