Sanders and Alston were in prison after being convicted of
assault. They were charged with assaulting another inmate, Jenkins, with
a shank, and possession of said shank.
Sanders argued that it was self-defense.
At trial, the prosecution attempted to introduce evidence
of Sanders' prior convictions.
Sanders argued that this was prejudicial and was
inadmissible
The prosecution argued that under FRE 609(a) and FRE
404(b), they were allowed to impeach a witness' credibility by
introducing evidence of prior convictions.
The theory was that the fact that Sanders had assaulted
people in the past made his self-defense claim less credible.
The Trial Judge allowed the evidence to be admitted.
Although only the evidence of convictions was admissible,
other evidence of crimes where Sanders was arrested but not convicted was
not admissible.
The Trial Court convicted Sanders of assault and
possession of contraband. He appealed.
The Appellate Court reversed the decision to admit the
evidence.
The Appellate Court looked at FRE 609(b)(1), which
says that evidence of prior convictions is only admissible if the
probative value of admitting the evidence outweighs its prejudicial
effect. They found that the probative value was small, and therefore the
evidence was not admissible under FRE 609(a).
In addition, there was no evidence that the Trial Judge
had attempted to perform a balancing test.
The Appellate Court noted that FRE 404(b) cannot
be used to show the character of the person, it can only be admissible
for other purposes. In this case they felt that the evidence
"proved only criminal disposition." Therefore it was
inadmissible.
His prior assault did not speak to his motive, intent or
plan to shank Jenkins. It only showed that he liked to stab people.
Had Sanders argued that he didn't know how to stab
someone, then the evidence would have been admissible to show that he
did possess the knowledge to stab someone. But Sanders admitted the
assault, so that wasn't an issue in this case.
The Court found that the error was reversible in the
charge of assault and remanded for a new trial, but was harmless error in
the charge of possession of contraband, so they affirmed that verdict.
