United States v. Sims, No. 11-2331 (6th Cir. 2013)
Annotate this CaseSims was set to go to trial on charges that he possessed child pornography (18 U.S.C. 2252(a)(4)(B) and (b)(2)), and that he attempted to produce child pornography (18 U.S.C. 2251(a) and (e)). Four days before trial he pled guilty to the possession charges. The district court then excluded the plea, expected testimony by the mother of one of the minors, and all evidence of Sims’s possession of child pornography from his attempted-production trial. The Sixth Circuit vacated and remanded. The trial court did not distinguish between the different types of evidence, incorrectly reasoning that the excluded evidence was relevant only to an issue that would not be important at trial: Sims’s intent. The intent element of the charged offense requires the government to prove that Sims specifically intended to obtain a lascivious image when he stood outside the minor’s bedroom window with a video camera. The district court erred, therefore, when it discounted the probative value of intent evidence in its balancing under Rule 403. The court’s reasoning did not adequately distinguish between prejudice that is unfair and prejudice that is fair with respect to the different types of evidence.
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