United States v. Robert Harrison, No. 22-1537 (8th Cir. 2023)
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A jury convicted Defendant of being a felon in possession of a firearm. The district court sentenced him to 84 months imprisonment. Harrison appealed, challenging the admission of evidence of his prior firearm conviction.
The Eighth Circuit affirmed. The court explained Defendant’s knowledge is at issue here because he did not plead guilty. Thus, Defendant’s prior conviction for unlawful possession of a firearm was relevant to prove knowledge. Further, Defendant’s conviction was not too remote in time. Although it occurred 8 years before his arrest in this case, he was incarcerated for more than 3 of those years. Therefore, based on its compliance with the requirements of Oaks, the court concluded the district court did not abuse its discretion in admitting evidence of Defendant’s prior firearm conviction.
Court Description: [Smith, Author, with Gruender and Stras, Circuit Judges] Criminal case - Criminal law. The district court did not err in admitting evidence of defendant's prior firearm conviction under Rule 404(b) as it was relevant to a material issue (knowledge), was similar to the crime charged here, was sufficiently established by the evidence submitted, and the balance of probative versus prejudicial value favored its admission; additionally, the district court addressed the issue of unfair prejudice by giving a limiting instruction. Judge Stras, concurring in the judgment.
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