FRE US v. Caldwell [609]

Question 1

Rule of law in US v. Caldwell?

Answer 1

Evidence of a criminal defendant’s prior conviction is admissible to impeach the defendant as a witness– if the probative value of the evidence outweighs its prejudicial effect. [Reverse 403]

Question 2

What test did the court use in US v. Caldwell?

Answer 2

Reverse 403

Question 3

What did the lower court err on in US v. Caldwell?

Answer 3

Allowed convictions under 404 ‘past bad acts/crimes’ under non-propensity reason of knowledge. ∆ never disputed knowledge of gun, he said it wasn’t his. Therefore, merely citing 404 exceptions is not enough, you must make the connections.

Question 4

Where did Caldwell appeal to from lower court?

Answer 4

3rd circuit

Question 5

What issues did 3rd circuit consider?

Answer 5

1. Must non-propensity purpose under 404 be in dispute to utilize the cited exception? [Yes]
2. 609 alternate arguments

Question 6

What test did court use to determine conviction admissibility under 609?

Answer 6

Jones Test:
1. Nature of conviction / value [Truth/violent]
2. Time passed
3. Similarity to charged crime [Similar bad]
4. Centrality of testimony

Question 7

What did court decide on caldwell’s past 609 convictions?

Answer 7

Under reverse 403, the PV did not outweigh its prejudicial effect.