United States v. John W. Wilson
966 F.2d 243 (1992)
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Rule of Law:
An objection to the admission of evidence based solely on 'relevance' under Federal Rule of Evidence 401 and 402 is insufficient to preserve for appeal an argument that the evidence should have been excluded under Rule 403 because its probative value was substantially outweighed by the danger of unfair prejudice. To preserve a Rule 403 claim, a party must specifically state unfair prejudice as the ground for the objection at trial.
Facts:
- Between January 1989 and January 1990, John W. Wilson engaged in a conspiracy to possess and distribute cocaine.
- During this conspiracy, Wilson supplied cocaine to his co-defendants, Moore and Gunn, often meeting at a Best Inn hotel for the transactions.
- In August 1989, an Illinois State Police Officer arrested Wilson.
- During an inventory search of the trunk of Wilson's car following the arrest, the officer discovered a duffle bag.
- Inside the duffle bag, the officer found cocaine, scales, empty plastic baggies, and a loaded nine-millimeter gun.
Procedural Posture:
- In November 1989, a jury convicted John W. Wilson of possession with intent to distribute cocaine and a firearm offense based on his August 1989 arrest ('possession conviction').
- While released on bond pending sentencing for the possession conviction, the government indicted Wilson and three co-defendants in January 1990 for conspiracy to distribute cocaine.
- Wilson's co-defendants pleaded guilty, and Wilson proceeded to a jury trial alone in the U.S. District Court (trial court) on the conspiracy charge.
- At trial, the government sought to introduce the gun found in Wilson's car; Wilson's counsel objected on relevance grounds, but the court overruled the objection.
- In May 1990, the jury convicted Wilson of the conspiracy charge.
- The district court sentenced Wilson to 147 months imprisonment.
- Wilson (appellant) appealed his conviction and sentence to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does a defendant's objection to the admission of evidence on the sole ground of 'relevance' preserve for appeal an argument that the evidence's probative value was substantially outweighed by the danger of unfair prejudice under Federal Rule of Evidence 403?
Opinions:
Majority - Manion, Circuit Judge.
No. A defendant's objection to evidence on the sole ground of relevance does not preserve for appeal an argument based on unfair prejudice under Rule 403. Federal Rule of Evidence 103(a)(1) requires a party to state the 'specific ground of objection' to preserve an issue for appeal. An objection on 'relevance' directs the court to Rules 401 and 402, which concern whether evidence has any tendency to prove a fact at issue. In contrast, Rule 403 allows for the exclusion of relevant evidence if its probative value is substantially outweighed by unfair prejudice. Because Wilson's counsel only objected on relevance grounds, he failed to alert the trial court to the distinct issue of unfair prejudice, thereby waiving the Rule 403 argument for appeal. As the issue was not preserved, the court's review is limited to 'plain error,' which requires showing that 'but for' the admission of the gun, Wilson 'probably would have been acquitted.' Given the overwhelming evidence of guilt, including testimony from two co-conspirators and corroborating physical evidence, the admission of the gun did not constitute plain error.
Analysis:
This decision reinforces the critical importance of specificity in evidentiary objections under the Federal Rules of Evidence. It clarifies that 'relevance' and 'unfair prejudice' are distinct legal grounds and that a general objection on one does not preserve the other for appeal. This holding serves as a practical guide for trial attorneys, emphasizing that they must explicitly invoke Rule 403's balancing test to give the trial court an opportunity to rule on the issue and to avoid waiver. By applying the stringent 'plain error' standard to the waived objection, the court underscores the high bar appellants face when trying to overcome procedural defaults at trial.
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