Huddleston v. United States, 485 U.S. 681 (1988), was a case in which the United States Supreme Court held that before admitting evidence of extrinsic acts under Rule 404(b) of the Federal Rules of Evidence, federal courts should assess the evidence's sufficiency under Federal Rule of Evidence 104(b). Under 104(b), "[w]hen the relevancy of evidence depends upon the fulfillment of a condition of fact, the court shall admit it upon, or subject to, the introduction of evidence sufficient to support a finding of the fulfillment of the condition."
Conviction affirmed by the Sixth Circuit, 811 F.2d 974 (6th Cir. 1987).
Holding
Evidence of other acts is admissible in federal court to show motive, opportunity, intent, preparation, plan, knowledge, or identity, and without a threshold determination that the acts have been proven.
Huddleston was being tried for selling stolen goods and possessing stolen goods, related to two portions of a shipment of Memorexvideocassettes that had been stolen from the Overnight Express yard in South Holland, Illinois.[1] 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. Instead, he contested a crucial element of the charged crimes — whether he knew that the cassettes had been stolen.[2]
To prove that he knew the cassettes were stolen, the government sought to introduce two pieces of relevant "similar acts" evidence. 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.[2]
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 an acquittance of Huddleston's had brought part of a shipment of appliances that had been stolen.[2]
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.[2]
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.[3]
Decision of the Court
The Supreme Court agreed to hear the case "to resolve a conflict among the Courts of Appeals as to whether the trial court must make a preliminary finding before 'similar act' and other Rule 404(b) evidence is submitted to the jury."[4]Chief Justice Rehnquist wrote for the unanimous court. Rule 404 of the Federal Rules of Evidence states:[5]
Other crimes, wrongs, or acts. — Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.
"Extrinsic acts evidence may be critical to the establishment of the truth as to a disputed issue, especially when that issue involves the actor's state of mind and the only means of ascertaining that mental state is by drawing inferences from conduct."[4] The Court held that extrinsic acts which are only relevant on the condition that a separate fact is proven true—such as Huddleston's previous sale of televisions—are "dealt with under Federal Rule of Evidence Rule 104(b)."[6] Rule 104(b) states that "[w]hen the relevancy of evidence depends upon the fulfillment of a condition of fact, the court shall admit it upon, or subject to, the introduction of evidence sufficient to support a finding of the fulfillment of the condition."[7] The Court reasoned that the text of 404(b) "contain[ed] no intimation . . . that any preliminary showing is necessary before such evidence may be introduced for a proper purpose" and rejected the petitioners argument that the issue should be governed under the stricter Rule 104(a) preponderance standard.[8]
Thus, the Court held the evidence was properly admitted.[9]
Impact
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.[10] 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.[11]
^Imwinkelried, The Need to Amend the Federal Rule of Evidence 404(b): The Threat to the Future of the Federal Rules of Evidence, 30 Vill. L. Rev. 607-611 (1985)
External links
Text of Huddleston v. United States, 485U.S. 681 (1988) is available from:CourtListenerFindlawGoogle ScholarJustiaLibrary of CongressOyez (oral argument audio)
Case brief
August 22, 2023
huddleston, united, states, 1988, case, which, united, states, supreme, court, held, that, before, admitting, evidence, extrinsic, acts, under, rule, federal, rules, evidence, federal, courts, should, assess, evidence, sufficiency, under, federal, rule, eviden. Huddleston v United States 485 U S 681 1988 was a case in which the United States Supreme Court held that before admitting evidence of extrinsic acts under Rule 404 b of the Federal Rules of Evidence federal courts should assess the evidence s sufficiency under Federal Rule of Evidence 104 b Under 104 b w hen the relevancy of evidence depends upon the fulfillment of a condition of fact the court shall admit it upon or subject to the introduction of evidence sufficient to support a finding of the fulfillment of the condition Huddleston v United StatesSupreme Court of the United StatesArgued March 23 1988Decided May 2 1988Full case nameGuy Rufus Huddleston v United States of AmericaCitations485 U S 681 more 108 S Ct 1496 99 L Ed 2d 771 1988 U S LEXIS 2035Case historyPriorConviction affirmed by the Sixth Circuit 811 F 2d 974 6th Cir 1987 HoldingEvidence of other acts is admissible in federal court to show motive opportunity intent preparation plan knowledge or identity and without a threshold determination that the acts have been proven Court membershipChief Justice William Rehnquist Associate Justices William J Brennan Jr Byron WhiteThurgood Marshall Harry BlackmunJohn P Stevens Sandra Day O ConnorAntonin Scalia Anthony KennedyCase opinionMajorityRehnquist joined by unanimousLaws appliedFed R Evid 404 b Contents 1 Facts 2 Decision of the Court 3 Impact 4 See also 5 References 6 External linksFacts EditHuddleston 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 1 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 Instead he contested a crucial element of the charged crimes whether he knew that the cassettes had been stolen 2 To prove that he knew the cassettes were stolen the government sought to introduce two pieces of relevant similar acts evidence 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 2 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 an acquittance of Huddleston s had brought part of a shipment of appliances that had been stolen 2 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 2 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 3 Decision of the Court EditThe Supreme Court agreed to hear the case to resolve a conflict among the Courts of Appeals as to whether the trial court must make a preliminary finding before similar act and other Rule 404 b evidence is submitted to the jury 4 Chief Justice Rehnquist wrote for the unanimous court Rule 404 of the Federal Rules of Evidence states 5 Other crimes wrongs or acts Evidence of other crimes wrongs or acts is not admissible to prove the character of a person in order to show action in conformity therewith It may however be admissible for other purposes such as proof of motive opportunity intent preparation plan knowledge identity or absence of mistake or accident Extrinsic acts evidence may be critical to the establishment of the truth as to a disputed issue especially when that issue involves the actor s state of mind and the only means of ascertaining that mental state is by drawing inferences from conduct 4 The Court held that extrinsic acts which are only relevant on the condition that a separate fact is proven true such as Huddleston s previous sale of televisions are dealt with under Federal Rule of Evidence Rule 104 b 6 Rule 104 b states that w hen the relevancy of evidence depends upon the fulfillment of a condition of fact the court shall admit it upon or subject to the introduction of evidence sufficient to support a finding of the fulfillment of the condition 7 The Court reasoned that the text of 404 b contain ed no intimation that any preliminary showing is necessary before such evidence may be introduced for a proper purpose and rejected the petitioners argument that the issue should be governed under the stricter Rule 104 a preponderance standard 8 Thus the Court held the evidence was properly admitted 9 Impact EditHuddleston 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 10 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 11 See also EditList of United States Supreme Court cases volume 485 List of United States Supreme Court cases Lists of United States Supreme Court cases by volume List of United States Supreme Court cases by the Rehnquist CourtReferences Edit Huddleston 485 U S at 682 a b c d Huddleston 485 U S at 683 Huddleston 485 U S at 684 a b Huddleston 485 U S at 685 Federal Rule of Evidence 404 b Huddleston 485 U S at 686 87 Federal Rule of Evidence Rule 104 b Huddleston 485 U S at 687 88 Huddleston 485 U S at 692 120 F R D 299 at 330 1988 Imwinkelried The Need to Amend the Federal Rule of Evidence 404 b The Threat to the Future of the Federal Rules of Evidence 30 Vill L Rev 607 611 1985 External links EditText 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 Retrieved from https en wikipedia org w index php title Huddleston v United States amp oldid 1057697761, wikipedia, wiki, book, books, library,
