United States v. Steven Washington
592 F.2d 680, 1979 U.S. App. LEXIS 16802 (1979)
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Rule of Law:
When evidence is admissible for one purpose but inadmissible for another, a trial judge commits a reversible error by refusing a defendant's request for a limiting instruction explaining the specific purpose for which the jury may consider the evidence.
Facts:
- Steven Washington was a passenger in a car with a suspected bank robber that attempted to elude federal officers in a high-speed chase.
- When the car was forced to stop, Washington exited the vehicle, pretended to surrender, and then fled into a crowd.
- Federal officers pursued Washington and cornered him in an alley.
- Washington brandished a gun at the approaching officers, at which point he was shot.
- Prior to this incident, Washington had been convicted of an unspecified felony.
Procedural Posture:
- The United States charged Steven Washington in a federal district court with assaulting federal officers and possession of a weapon by a convicted felon.
- At trial, the government introduced a stipulation that Washington had a prior felony conviction.
- Defense counsel requested a limiting instruction for the jury regarding the use of the prior conviction evidence, but the trial judge refused the request.
- A jury convicted Washington on both counts.
- Washington was sentenced to eight years imprisonment for assault and a suspended two-year sentence for the weapon possession charge.
- Washington (Appellant) appealed his conviction to the United States Court of Appeals for the Second Circuit.
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Issue:
Does a trial judge commit a reversible error by refusing a defendant's request for a limiting instruction when evidence of a prior felony conviction, admissible to prove an element of a charged crime, is inadmissible to show a general propensity to commit crimes?
Opinions:
Majority - Per Curiam
Yes, the trial judge's refusal to give the requested limiting instruction was a reversible error. Federal Rule of Evidence 105 mandates that when evidence is admissible for one purpose but not another, the court must, upon request, instruct the jury on its limited use. This circuit's precedent consistently requires a limiting instruction for prior criminal conduct evidence to prevent the jury from making an improper inference about the defendant's character or propensity to commit the charged crime. Even though the nature of the prior felony was not specified, the mere revelation of a prior felony conviction was prejudicial enough to entitle the defendant to the instruction. The court cannot conclude that this error was harmless and did not contribute to the verdict.
Analysis:
This decision reinforces the mandatory nature of Federal Rule of Evidence 105 regarding limiting instructions, establishing that a trial court has no discretion to refuse such a request when evidence of prior crimes is introduced. It underscores the high risk of unfair prejudice inherent in informing a jury of a defendant's criminal history, even when necessary to prove an element of an offense like 'felon in possession.' The ruling makes clear that failure to give a requested limiting instruction is a significant error that is unlikely to be considered harmless on appeal, thereby providing a strong protection for defendants against the misuse of character evidence.
