USA v. Valenzuela, No. 21-51215 (5th Cir. 2023)
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Defendant appealed her conviction for possession and smuggling of controlled substances. Defendant asserts that the trial court abused its discretion in admitting evidence of a prior drug smuggling offense under Rule 404(b) of the Federal Rules of Evidence. Defendant argued that evidence of her prior crime is irrelevant because it is too dissimilar to the subsequent trafficking crime. Defendant further argued that the prejudicial effect of the extrinsic evidence far outweighs its probative value, thus failing Rule 403’s balancing test and Beechum’s second step.
The Fifth Circuit affirmed. The court concluded that the district court did not abuse its discretion either in finding that the prior criminal act was relevant to Defendant’s knowledge in the instant drug trafficking case or in finding that the prejudicial effect of the evidence did not substantially outweigh its probative value. The government’s closing argument offered the extrinsic evidence not to mislead the jury into convicting her for a previous offense, but to show absence of mistake, which Rule 404(b) specifically allows. The district court also mitigated any misuse by providing a limiting instruction cautioning the jury that Defendant was “not on trial for any other act, conduct or offense not alleged in the indictment.”
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