United States v. Leonard Peltier
585 F.2d 314 (1978)
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Rule of Law:
Under Federal Rules of Evidence 404(b) and 403, evidence of other crimes, wrongs, or acts is admissible if it is offered for a proper purpose, such as proving motive or consciousness of guilt, and its probative value is not substantially outweighed by the danger of unfair prejudice.
Facts:
- In June 1975, FBI Special Agents Jack Coler and Ronald Williams were on the Pine Ridge Indian Reservation attempting to locate and arrest four individuals, including James Theodore Eagle.
- On June 26, 1975, the agents followed a red and white van, occupied by Leonard Peltier, Norman Charles, and Joseph Stuntz, into the Harry Jumping Bull Compound.
- Shortly after the agents and the van stopped, a firefight erupted between the agents and members of the American Indian Movement (AIM), including Peltier, who were present in the compound.
- During the shootout, both agents were wounded by shots fired from a distance.
- After being incapacitated, both agents were killed by shots fired from a high-velocity, small-caliber weapon at point-blank range to their heads.
- An eyewitness, Michael Anderson, saw Peltier, Robert Robideau, and Darrell Butler standing near the agents' cars after the initial shootout; Peltier was holding an AR-15 rifle.
- A .223 caliber cartridge casing found in the trunk of Agent Coler's car was ballistically linked to the AR-15 rifle associated with Peltier.
- Months later, when stopped by Oregon State Police, Peltier fled. A subsequent search of the motor home he had been in revealed Agent Coler's revolver inside a paper bag bearing Peltier's thumbprint.
Procedural Posture:
- Leonard Peltier, Robert Eugene Robideau, Darrell Dean Butler, and James Theodore Eagle were charged with two counts of first-degree murder in a U.S. District Court.
- Robideau and Butler were jointly tried by a jury and were acquitted.
- The government dismissed the charges against Eagle.
- Peltier was subsequently tried by a jury in the U.S. District Court for the District of North Dakota.
- The jury convicted Peltier on both counts of first-degree murder.
- The trial court sentenced Peltier to two consecutive terms of life imprisonment.
- Peltier (appellant) appealed the judgment of conviction to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Did the trial court abuse its discretion by admitting evidence of the defendant's outstanding arrest warrant, subsequent flight from law enforcement, and possession of numerous weapons unrelated to the murders charged?
Opinions:
Majority - Ross, Circuit Judge
No. The trial court did not abuse its discretion in admitting the challenged evidence. Evidence of other crimes, wrongs, or acts is admissible under Rule 404(b) for purposes other than proving character, such as establishing motive or consciousness of guilt, so long as its probative value is not substantially outweighed by the danger of unfair prejudice under Rule 403. The court found that Peltier's outstanding arrest warrant for attempted murder was highly probative of his motive to react with deadly force against law enforcement officers. Similarly, evidence of his flight in Oregon, which included possession of numerous weapons and the victim's service revolver, was highly probative of a consciousness of guilt. The court reasoned that while some weapons evidence may have been cumulative or of questionable relevance, its admission constituted harmless error in light of the vast amount of other properly admitted firearms evidence and the strong overall evidence of Peltier's guilt. Finally, the trial court acted within its discretion by excluding defense evidence of alleged FBI misconduct involving other individuals (Myrtle Poor Bear and Jimmy Eagle), as this evidence was only minimally relevant, potentially confusing to the jury, and cumulative.
Analysis:
This case strongly affirms the broad discretion afforded to trial judges under Federal Rules of Evidence 403 and 404(b) in admitting evidence of a defendant's other crimes or bad acts. The decision demonstrates that even highly prejudicial evidence, such as an unrelated attempted murder charge and the possession of an arsenal of weapons, can be deemed admissible if the prosecution successfully links it to a permissible, non-propensity purpose like motive or consciousness of guilt. It sets a high bar for defendants seeking reversal on evidentiary grounds, reinforcing the concepts of harmless error and deference to the trial court's balancing of probative value against unfair prejudice, especially in cases where the overall evidence of guilt is substantial.
