United States v. Clay, No. 09-5568 (6th Cir. 2012)
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After a man stole a car at gunpoint, the FBI agent learned that about an hour later someone attempted to use the owner's stolen bank cards. Surveillance video showed an unshaven, African American man wearing a red and white patterned shirt and a hooded jacket. Agents found the car in an apartment complex parking lot, searched the apartment and found the keys and items stolen in another robbery. They arrested defendant in the apartment and, in the car, found pictures of defendant, wearing the patterned shirt. Other items in the car were traceable to similar car thefts. At trial on charges of carjacking (18 U.S.C. 2119) and brandishing a firearm during a crime of violence (18 U.S.C. 924(c)(1)(A)(ii)) the court admitted evidence of a 2006 assault and of the uncharged theft of a gun from another car, under the res gestae doctrine and 404(b), and issued a limiting instruction. Defendant was convicted and sentenced to 360 months of imprisonment. The Sixth Circuit reversed. The evidence was sufficient to allow a rational fact-finder to infer that defendant was guilty, but the court improperly admitted evidence of the gun theft and the prejudicial impact was high.
The court issued a subsequent related opinion or order on April 19, 2012.
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