United States v. Adams, No. 14-2149 (8th Cir. 2015)
Annotate this CaseDetectives approached people in Kinlock, Missouri, after observing apparent drug transactions. Seeing the detectives, Adams clutched his waistband and fled. Detective Hinds testified that, while in pursuit, he saw Adams brandish a semi-automatic pistol and point it at the detectives. Hinds signaled to the other detectives that he saw a firearm and ordered Adams to drop it. Adams did not comply. Hinds fired two rounds at Adams. According to several detectives, Adams dropped the firearm. Detective Becker stayed with the weapon while others continued the pursuit and apprehended Adams. Both detectives testified that while in custody, Adams made incriminating statements. Adams was indicted as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The government moved in limine to introduce, under Rule 404(b), evidence of a 2008 felon in possession conviction and a 2005 conviction for carrying a concealed weapon, to prove his knowledge of firearms and his intent to possess a firearm. After Adams's defense elicited testimony, questioning whether Adams actually possessed the firearm, the court granted the motion, stating that "do we really think that there's anybody in the world who doesn't know what a gun is … it's … really saying propensity." The judge noted that Eighth Circuit precedent supporting admission of such evidence is ample, and “I'm just trying to ask for an explanation.” The court twice gave a limiting instruction that the jury could only consider Adams's prior convictions to show his knowledge or intent, not to show propensity. The Eighth Circuit affirmed.
Court Description: Criminal Case - conviction. District court did not abuse its discretion in allowing admission of prior illegal firearms convictions, even after stating misgivings about its potential for unfair prejudice. Any error was harmless. Evidence had probative value to show knowledge and intent.
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