Huddleston v United States

A Case Briefing

Citation

Huddleston v United States, 485 U.S. 681 (Federal District Court of Appeals, Sixth Circuit 1988)

Parties

Parties involved include the appellant, Huddleston and the United States, appellee. In the lower court, Huddleston was the defendant and the United States’ Government was the plaintiff.

Facts

In the underlying case, defendant Huddleston was charged with the knowing possession and attempted sale of over 32,000 stolen video tapes. Huddleston claimed he had no idea that the tapes were stolen, but had been given to him by another individual. The United States’ Government produced similar acts of evidence connecting Huddleston to the sale of stolen televisions appliances from the same store, deeming the evidence relevant in that the defendant would have known the video tapes were stolen. The defendant asserts that the introduction of this evidence was erroneous.

Procedure Below

Huddleston was tried and convicted by the lower court for the knowing possession of stolen goods.

Issue

Should the District Court make a preliminary finding that the plaintiff has proved the “other act” by a sufficient wealth of evidence prior to the submission of “similar acts” evidence to the jury?

Holding

No, a court is not required to make a preliminary finding of “other acts” by a preponderance of evidence before submitting “similar acts” and Rule 404 evidence to the jury. Similar acts of evidence can be submitted if ample evidence exists to support the jury finding the defendant committed the similar act.

Rationale

In this case, it was determined that the lower court appropriately allowed the evidence of prior television sales to go to jury. The jury could further reasonably connect the stolen televisions with the defendant’s low price sought for the televisions, his lack of bill of sale, and his involvement in the sales of stolen tapes.

Disposition

The court affirmed the lower court’s ruling in favor of the United States, holding that no preliminary finding is necessary for “other acts”; only sufficient evidence to connect to “similar acts.”