USA v. Long, No. 22-3033 (3d Cir. 2024)
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In this case, the United States Court of Appeals for the Third Circuit ruled on an appeal by the U.S Government against the decision of the United States District Court for the Western District of Pennsylvania to exclude certain evidence in a child pornography case involving Roderick Long. Long was indicted for knowingly possessing child pornography involving victims under 12 years old, and the evidence in question included a video montage and four photos alleged to have been found on Long's electronic devices. The District Court excluded the exhibits on the grounds of Rule 403, citing the risk of unfair prejudice, cumulativeness, wasting time, and potential jury confusion. However, the District Court made its decision without viewing the exhibits, relying on written descriptions provided by the parties.
The Court of Appeals held that the District Court had committed procedural error by not viewing the evidence before deciding on its admissibility, stating that it was far from obvious that the risk of unfair prejudice from the disturbing nature of the exhibits substantially outweighed their probative value. The Court of Appeals further noted that the cumulativeness, potential for wasted time, and possible jury confusion did not make it obvious that the exhibits failed Rule 403’s balancing test. The Court of Appeals therefore vacated the District Court's decision and remanded the case back to the District Court for a new Rule 403 balancing after viewing the exhibits proffered by the Government.
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