Old Chief v. United States

Supreme Court of the United States · 1997 · Evidence

519 U.S. 172 (1997)

Updated August 1, 2026

EvidenceRule 403stipulationsFederal Rules of EvidenceRule 401Rule 404(b)prior convictionfelon in possession

Facts

Old Chief was charged with violating 18 U.S.C. § 922(g)(1), which prohibits firearm possession by a person previously convicted of a crime punishable by imprisonment for more than one year. Before trial, he offered to stipulate or admit that he had such a qualifying prior conviction and asked the court to bar the Government from revealing the name and nature of that offense. The Government refused and introduced the judgment record showing that his prior conviction was for assault resulting in serious bodily injury. Old Chief objected that disclosing the name and nature of the prior assault created unfair prejudice, especially because he was also on trial for current assault-related charges.

Issue

When the Government offers a prior judgment record solely to prove the prior-conviction element of a § 922(g)(1) charge, does a district court abuse its discretion under Rule 403 by admitting the name and nature of the prior offense over the defendant's offer to admit or stipulate to the qualifying conviction? More broadly, may Rule 403 balancing consider less prejudicial evidentiary alternatives in assessing probative value?

Rule

Evidence of the name or nature of a defendant's prior offense is relevant to the prior-conviction element of § 922(g)(1), but under Rule 403 a court may compare the offered proof with available alternative proof. In a felon-in-possession case, when the purpose of the prior-conviction evidence is solely to prove legal status and the defendant offers an admission or stipulation that establishes the element, the probative value of the full judgment record is discounted; if the prior offense is likely to support an improper propensity inference, the danger of unfair prejudice substantially outweighs that discounted probative value, and admission of the full record is an abuse of discretion.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Detroit, Marcus Lane is tried for possessing a handgun after a prior conviction. He offers to admit that he has been convicted of a crime punishable by more than one year in prison, but the prosecutor insists on introducing a certified judgment showing that the prior offense was aggravated battery. The judgment is offered only to prove the status element.

Should the trial judge admit the full judgment record over Marcus's admission?

Explanation. The majority held that the name and nature of the prior offense remain relevant under Rule 401, but Rule 403 permits comparison with available alternatives. In a felon-in-possession prosecution, if the evidence is offered solely to prove status and the defendant offers an admission establishing the qualifying conviction, the probative value of the full judgment is discounted. If the offense name creates a propensity risk, unfair prejudice substantially outweighs that discounted value, so admission is an abuse of discretion.