The Law School Authority

United States v. Beasley Case Brief

Summary of United States v. Beasley, 809 F.2d 1273 (7th Cir. 1987)

Facts:  D, a biochemist, got a prescription form a physician for some drugs by informing the physician that he was going to use the drugs for some experiment.  But according to the prosecution, D sold the drugs for illegal use.  Major part of prosecution was based on the testimony of a convicted drug dealer and fearing that the jury might trust D, a reputable biochemist, and not the drug dealer, prosecution introduced evidence of prior drug dealings conducted by D.

Issue:  Was the evidence of prior drug dealings of D properly admitted here?

Holding: No

Rationale: There is a two part test to see if prior crime evidence properly admitted under Rule 402(b): 1. it must be determined that the extrinsic offense evidence is relevant to an issue other than the D’s character.  2. The evidence must possess probative value that is not substantially outweighed by the undue prejudice.  Here the prosecution argues that evidence showed a pattern.  But pattern is not an exception and pattern just shows that propensity of the D to commit the crime he is charged with, which is strictly prohibited under the rule.  Such evidence can be used to prove intent, especially in this case where D claims that he bought the drugs to conduct some scientific experiment.  But the trial judge has to weigh the benefits of the evidence for intent purposes against the danger of prejudice.  Here the trial judge completely failed to conduct such balancing test.  Therefore, the case is remanded.

Note: Evidence of other crimes may be admissible to show proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.

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