United States v. Hall, Jr., No. 15-4720 (4th Cir. 2017)Annotate this Case
Defendant was convicted of various drug and firearm offenses. The Fourth Circuit held that the district court abused its discretion by admitting evidence of prior convictions under FRE 404(b) where the government proffered no evidence of any connection between defendant's prior possession conviction and the instant charge; that possession conviction was not relevant to whether defendant intended to distribute the marijuana found inside the locked bedroom; and there was a lack of factual similarity and temporal proximity between defendant's prior convictions and his present convictions. Furthermore, the minimal probative value of admitting the convictions was substantially outweighed by the likelihood of unfair prejudice. Accordingly, the court reversed, vacated, and remanded.