Boyd v. United States
1892 U.S. LEXIS 1983, 142 U.S. 450, 12 S. Ct. 292 (1892)
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Rule of Law:
Evidence of prior, unrelated crimes committed by a defendant is generally inadmissible at trial for a different offense, as such evidence is collateral to the issue being tried and its primary effect is to unfairly prejudice the jury against the defendant.
Facts:
- In March 1890, Eugene Standley, sometimes with John Boyd, allegedly committed a series of robberies against Richard Brinson, Samuel Mode, Robert Hall, and John Taylor.
- On the evening of April 5, 1890, Boyd, Standley, and a man named Davis allegedly robbed Rigsby's store.
- On the night of April 6, 1890, Boyd, Standley, and Davis went to a ferry on Cache Creek operated by Martin Byrd and asked to be taken across.
- Byrd went to his house and returned with three other armed men, including John Dansby.
- An altercation began when Davis, one of Boyd's companions, attempted to rob Byrd.
- A shootout ensued, during which Boyd shot Dansby in the back.
- Dansby died from his wounds a few days later.
Procedural Posture:
- John Boyd and Eugene Standley were jointly indicted for the murder of John Dansby in the U.S. District Court for the Western District of Arkansas, a federal trial court.
- At trial, the prosecution called Martin Byrd as a witness, who had a prior felony conviction for larceny.
- The defendants objected to Byrd's competency as a witness, but the court allowed his testimony after the prosecution produced a full and unconditional pardon from the President of the United States.
- The prosecution introduced evidence detailing several robberies committed by the defendants prior to the date of the alleged murder.
- The defendants objected to the admission of evidence related to the robberies of Brinson, Mode, and Hall, but the trial court overruled the objection and admitted the evidence.
- The jury found the defendants guilty of murder as charged in the first count.
- The defendants' motion for a new trial was denied, they were sentenced to death, and they subsequently appealed their conviction to the Supreme Court of the United States.
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Issue:
Does the admission of evidence of prior, unrelated crimes, which are not connected to the crime charged and serve only to portray the defendant as a person of bad character, constitute a reversible error depriving the defendant of a fair trial?
Opinions:
Majority - Mr. Justice Harlan
Yes, the admission of such evidence constitutes a reversible error. Evidence of prior crimes committed by the defendants that are wholly separate from the crime charged is inadmissible. Such evidence is collateral to the issue being tried—in this case, the murder of Dansby—and affords no legal presumption of guilt for the specific offense charged. While evidence of some crimes (like the Rigsby robbery) might be admissible for a specific, limited purpose such as proving identity, evidence of other, more remote robberies (like those of Brinson, Mode, and Hall) serves no purpose other than to prejudice the jurors, draw their minds away from the real issue, and suggest that the defendants are 'wretches' with a propensity for crime. No matter their past, the defendants were entitled to be tried upon competent evidence relating only to the offense for which they were indicted.
Analysis:
This case strongly affirms the common law principle against the use of propensity evidence in criminal trials, a cornerstone of evidence law now codified in Federal Rule of Evidence 404(b). The Court's decision underscores that a defendant must be convicted based on evidence of the specific crime charged, not on their past character or unrelated criminal history. This precedent protects the presumption of innocence and prevents the jury from convicting a defendant simply because they believe them to be a 'bad person.' It sets a clear boundary on the admissibility of 'other acts' evidence, allowing it only when it serves a specific, relevant purpose other than proving character, and even then, its prejudicial effect must be carefully weighed.
