United States v. Krapp
815 F.2d 1183 (1987)
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Rule of Law:
Under Federal Rule of Evidence 404(b), evidence of a defendant's prior uncharged acts is admissible to prove intent and absence of mistake, provided it is relevant to an issue other than character, is supported by clear and convincing evidence, and its probative value is not substantially outweighed by the risk of unfair prejudice.
Facts:
- Patricia E. Krapp served as the postmaster for the Pocahontas, Iowa post office from November 1983 to February 1986.
- A postal inspection in January 1986 revealed a shortage of 100 coils of stamps, valued at $2,200.
- Krapp admitted to investigators that she had discovered the shortage in late 1985 but had not recorded it on official postal forms and reports as required.
- Krapp claimed she did not report the shortage because she was investigating the matter and lacked expertise in completing the required forms.
- At trial, the prosecution introduced evidence of other postal regulation violations committed by Krapp.
- These other violations included failing to collect certain postage, improperly borrowing travel money from an account, failing to replace a drawer shortage, and improperly auditing an employee's drawer.
Procedural Posture:
- Patricia E. Krapp was charged with three counts of making false record entries in the U.S. District Court for the Northern District of Iowa, a federal trial court.
- Prior to trial, Krapp filed a motion in limine to exclude evidence of other postal violations, but the judge did not rule on it and she did not renew the motion at trial.
- During the trial, the prosecution cross-examined Krapp's character witness with a question about her tax returns, leading to an objection and a motion for a mistrial, which the court denied.
- The jury convicted Krapp on all three counts.
- Krapp (as appellant) appealed her conviction to the U.S. Court of Appeals for the Eighth Circuit, arguing that the trial court erred in admitting the other acts evidence, refusing a mistrial, and failing to give a specific jury instruction on character evidence.
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Issue:
Is evidence of a defendant's prior, uncharged violations of work regulations admissible under Federal Rule of Evidence 404(b) to prove intent and lack of mistake in a prosecution for making false record entries?
Opinions:
Majority - Ross, J.
Yes. Evidence of a defendant's prior violations is admissible under Federal Rule of Evidence 404(b) when used to demonstrate intent and rebut a defense of mistake. The court found the evidence of Krapp's other postal regulation violations met the three-part test for admissibility. First, it was relevant to proving her intent and lack of mistake, directly countering her defense that she was merely inexperienced with procedures. Second, the other acts were established by clear and convincing evidence, including Krapp's own admissions. Third, the probative value of the evidence was not outweighed by its potential for unfair prejudice, especially since the acts were recent and the trial court provided a limiting instruction to the jury, directing them to consider the evidence only as it related to Krapp's state of mind.
Analysis:
This case reinforces the broad, inclusionary scope of Federal Rule of Evidence 404(b), which permits the admission of 'other acts' evidence for non-propensity purposes. It demonstrates how such evidence can be a powerful tool for prosecutors to rebut a defendant's claim of mistake or lack of intent. The court's application of the three-part test—relevance, clear evidence, and a balancing of probative value against prejudice—serves as the critical safeguard. The decision also underscores the importance of a trial court's limiting instruction as a means to mitigate the prejudicial effect of such evidence, often making the admission of the evidence permissible on appeal.
