Old Chief v. United States
Citation: 519 U.S. 172 (U.S. Supreme Court, 1997)
Facts
Johnny Old Chief was charged with assault with a dangerous weapon and with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1), which required proof of a prior felony conviction. Old Chief offered to stipulate to the existence of the prior conviction to prevent the jury from learning its nature — a prior assault conviction — which he feared would be unfairly prejudicial. The government refused, and the district court allowed it to prove the prior conviction by introducing the record of the judgment.
Issue
Whether a district court abuses its discretion under FRE 403 by admitting the full record of a prior conviction when the defendant offers to stipulate to the fact of the conviction.
Holding
The Supreme Court held that the district court abused its discretion. When a defendant charged as a felon-in-possession offers to stipulate to his prior felony status, the government’s interest in proving the nature of the prior crime is substantially outweighed by the unfair prejudice of admitting the full record, and the stipulation provides an adequate substitute for the full evidentiary detail.
Rule
Under FRE 403, courts must weigh probative value against unfair prejudice. When a defendant offers to stipulate to an element, the stipulated admission reduces (but does not eliminate) the probative value of the underlying evidence. If a less prejudicial substitute provides equivalent proof of the same fact, the full evidentiary detail may be excluded. This principle applies especially to status elements like prior conviction in felon-in-possession cases.
Significance
Old Chief is the central FRE 403 case taught in Evidence courses. It demonstrates the balancing inquiry in concrete terms, addresses the prosecution’s interest in narrative coherence, and establishes the important principle that the availability of a stipulation can reduce the probative value of otherwise admissible evidence.