Huddleston v. United States

485 U. S. 681

May 2, 1988

~~~ Antonin Scalia – Requiescat In Pace ~~~

Guy Rufus Huddleston was charged with selling stolen property – namely, thousands of blank VHS tapes (anyone remember those?). Huddleston claimed that he didn’t know they were stolen, and so the government introduced evidence that Huddleston had sold large quantities of appliances under shady circumstances on at least two other occasions. Under the Federal Rules of Evidence, other crimes can be introduced as evidence to prove knowledge; in this case that Huddleston definitely knew the tapes were stolen. But Huddleston said that under the Rules, this evidence could only be admitted after the Court made a preliminary finding away from the jury, and by a preponderance standard, that the previous items had actually been stolen.

The Supreme Court unanimously ruled against Huddleston. Rehnquist said that any allowable relevant evidence may be introduced, without a preliminary finding, if the court is satisfied that the evidence is more probative than prejudicial. The structure of the Rules and legislative history made this plain. The Rules further mandated that if evidence’s relevance depended on a fact being true, the court should allow it if a reasonable jury might think that fact was established. Rehnquist said a reasonable jury could indeed conclude that the appliances were stolen, and thus the evidence was properly admitted to show knowledge. I have no objection to this ruling (as I’ve mentioned before, I’m very liberal when it comes to admitting evidence). I am rather shocked that Brennan and Marshall went along with it. My hunch is that one of them started writing a dissent, only to be told by the other to ‘let this one go.’


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