Old Chief v. United States Case Brief

Why is the case important?

The defendant, Old Chief (the “defendant”) was arrested after an incident involving at least one gun shot.

Facts of the case

Johnny Lynn Old Chief was involved in a disturbance involving gunfire. Subsequently, Old Chief was charged with violating federal law, 18 U. S. C. Section(s) 922(g)(1), which prohibits possession of a firearm by anyone with a prior felony conviction. The earlier crime that was charged in the indictment against Old Chief was assault causing serious bodily injury. Old Chief moved for an order requiring the Government to refrain from revealing the name and nature of his prior assault conviction, which, he argued, would unfairly tax the jury’s capacity to hold the Government to its burden of proof beyond a reasonable doubt, in violation of Federal Rules of Evidence, on current charges of assault, possession, and violence with a firearm. Old Chief offered to stipulate, or concede, to the fact of the prior conviction without releasing its name or nature. The Government refused to join the stipulation. The Government argued it had the right to present its own evidence of the prior conviction. The District Court ruled in favor of the Government. In affirming the conviction, the Court of Appeals found that the Government was entitled to introduce probative evidence to prove the prior offense regardless of the stipulation offer.

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Conclusion

The Court held that in general, if a defendant to a 922(g)(1) charge offers to concede the fact of a prior qualifying conviction, then under Rule 403 , it is an abuse of discretion for the trial judge, in balancing probative value against the danger of unfair prejudice, to spurn the defendant’s offer and to admit the full record of the prior judgment of conviction, where the name and nature of the prior offense raise the risk of a verdict tainted by improper considerations, and the purpose for the government’s introduction of such evidence is solely to prove the element of prior conviction. In so doing, the Court ruled that the District Court had abused its discretion under Rule 403 in the case at hand.

  • Case Brief: 1997
  • Petitioner: Old Chief
  • Respondent: United States
  • Decided by: Rehnquist Court

Citation: 519 US 172 (1997)
Argued: Oct 16, 1996
Decided: Jan 7, 1997