Huddleston v. United States
Citation: 485 U.S. 681 (U.S. Supreme Court, 1988)
Facts
Huddleston was charged with possessing and selling stolen videocassette tapes. To prove knowledge that the tapes were stolen, the government offered evidence that Huddleston had sold other stolen goods — specifically, stolen televisions — on a prior occasion. The prior act had not resulted in a conviction, and Huddleston argued the evidence was inadmissible unless the government first proved by clear and convincing evidence that the prior act occurred.
Issue
What standard of proof must the government satisfy before introducing evidence of prior bad acts under FRE 404(b), and who decides whether the prior act occurred — judge or jury?
Holding
The Supreme Court held that Rule 404(b) evidence requires only that the trial judge find sufficient evidence for a reasonable jury to conclude the prior act occurred by a preponderance of the evidence. The jury, not the judge, ultimately determines whether the prior act occurred, applying the conditional relevance framework of FRE 104(b).
Rule
Under FRE 404(b), prior act evidence is admissible for permissible non-character purposes (knowledge, intent, motive, identity, etc.) if the trial court determines there is sufficient evidence for a jury to find the prior act occurred. The judge applies the conditional relevance standard of Rule 104(b), not the Rule 104(a) preponderance standard. The court must also balance probative value against unfair prejudice under Rule 403.
Significance
Huddleston is the foundational case for the admissibility of FRE 404(b) other acts evidence. It clarifies the allocation of responsibilities between judge and jury and establishes the relatively permissive conditional relevance standard, making it central to understanding how courts admit or exclude prior bad acts evidence.