Huddleson v. United States
485 U.S. 681, 108 S.Ct. 1496, 99 L.Ed.2d 771 (1988)

  • Someone stole a truckload of blank videotapes.  A few days later, Huddleson showed up selling large numbers of blank videotapes.  He was arrested on suspicion of selling stolen property.
    • Huddleson argued that he was selling the videotapes on commission for a guy named Wesby and had no idea that they’d been stolen.
  • At trial, the prosecution attempted to offer evidence about two prior dealings between Huddleson and Wesby.
    • Huddleson acted as Wesby’s agent and sold a bunch of televisions to a guy named Tomey.  It was a very suspicious transaction, but there was never proof that the televisions had been stolen.
    • Huddleson acted as Wesby’s agent and sold a bunch of appliances to Nelson.  The appliances turned out to be stolen.
    • Btw, one of these events happened before Huddleson was arrested for the videotape sale, the other event happened afterwards.  But that doesn’t matter for the purposes of the final ruling in this case.
  • The prosecution argued that the prior acts were admissible because they showed that Huddleson knew Wesby trafficked in stolen goods.
    • Huddleson objected on the grounds that the evidence was inadmissible.
    • The prosecution argued that it was admissible under FRE 404(b).
  • The Trial Judge allowed the evidence to be admitted, but issued a limiting instruction to the jury that it was only to be used to show Huddleson’s knowledge, not his character.
  • The Trial Court convicted Huddleson for possession of stolen goods.  He appealed.
    • Huddleson argued that the evidence about the televisions should not have been admitted because there was no evidence that the televisions had been stolen.  Therefore it was not a “similar act” as required by FRE 104(a), and did not show that Huddleson had knowledge that Wesby sold stolen goods.
      • FRE 104(a) requires that the party prove by a preponderance of evidence that the crime had been committed.
  • The Appellate Court affirmed.
  • The US Supreme Court affirmed.
    • The US Supreme Court found that evidence should be admitted if there is sufficient evidence to support a finding by a jury that the defendant committed the similar act.
    • Basically, the Court said that a prior act does not have be proved by the preponderance of the evidence in order to be admissible.  As long as there is enough evidence that a reasonable jury could theoretically find by a preponderance of the evidence that the defendant committed the act, the evidence can be admitted.  The opposing party is free to argue how much weight to give it.
      • In this case, even though Huddleson was never charged with selling stolen televisions, the low price he was selling them for, the large quantity he was selling, and his inability to produce a bill of sale made it reasonable that a jury could have found him guilty of selling stolen televisions.  Therefore, the evidence is admissible as a similar act under FRE 404(b).
    • The Court found that under FRE 104(b) the Trial Judge should not weigh credibility, but determines only whether a reasonable juror could conclude that the defendant committed the uncharged act, and should submit it to the jury for consideration with an instruction that:
      • Before they can consider the evidence they have to be convinced by a preponderance of the evidence that he committed the act and
      • They may use it only for a limited purpose.