United States v. Valencia

61 F.3d 616 (8th Cir. 1995)

Facts

Valencia (D) was arrested and charged with conspiracy to possess and intent to distribute cocaine, and money laundering. Witnesses gave evidence that D was the California connection for various North Dakota drug dealers. During trial evidence pursuant to 404(b) was ruled inadmissible under a 403 analysis. However, the judge cited that the evidence might be admissible under 609. It was later admitted. D was convicted. D appealed citing the admission of a prior conviction under Rule 609.