United States v. Armajo, No. 21-8021 (10th Cir. 2022)
Annotate this CaseIn his trial for assaulting his uncle with a knife, defendant-appellant Shayne Armajo sought to introduce evidence of his uncle’s assaults in order to bolster a self-defense claim. The issue defendant’s appeal presented for the Tenth Circuit’s consideration was whether the district court abused its discretion when it ruled that this was a permissible use under Rule 404(b) but nevertheless excluded most of the proffered evidence under Rule 403 because its probative value was substantially outweighed by the risk of undue prejudice. Evidence of a victim’s prior violent acts may be admissible in a self-defense case to prove the defendant’s state of mind, but it is subject to Rule 403’s balancing test. As applied here, the Court found the district court reasonably concluded that the probative value of the victim’s alleged assaults was substantially outweighed by the risk of unfair prejudice. Consequently, the Court held the district court did not abuse its discretion when it excluded the contested evidence.
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