Eady v. United States
44 A.3d 257
| D.C. | 2012Background
- Appellant Carlos Eady was convicted by a DC jury of carrying a pistol without a license (CPWL), possession of an unregistered firearm (UF), and possession of ammunition (UA).
- The CPWL conviction carried a sentencing enhancement for a prior felony conviction and for committing the offense while on release.
- The indictment and trial proceeded with evidence that Eady was on release in another case when he allegedly committed the CPWL offense.
- The trial court admitted evidence and allowed argument about Eady's prior felony and on-release status, based on stipulations the parties agreed to.
- The court read the unredacted indictment to the jury, which described the prior felony and the release scenario, and the government emphasized these points in opening, during trial, and in closing.
- A plain-error review found that the repeated disclosures of prior crimes and release status prejudiced Eady and denied him a fair trial, requiring reversal and remand for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admission of prior conviction and release evidence was plain error | Eady | Eady | Yes; plain error |
| Whether stipulations cured or mitigated the error | Eady | US | No; still prejudicial plain error |
| Whether the trial court should have instructed the jury differently or limited the use of other-crimes evidence | Eady | US | Yes; error required reversal |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (any fact increasing penalty beyond maximum must be jury-found)
- Old Chief v. United States, 519 U.S. 172 (1997) (admit felon status via stipulation to avoid prejudice; balance probative value)
- Tansimore v. United States, 355 A.2d 799 (DC 1976) (release-status enhancement is sentencing matter, not offense element)
- Coleman v. United States, 552 F.3d 853 (DC Cir. 2009) (unredacted indictment reading prejudicial when prior conviction type is similar to charged offense)
- Harris v. United States, 536 U.S. 545 (2002) (Apprendi framework applies to other enhancements; danger of prejudice)
- Drew v. United States, 331 F.2d 85 (D.C. Cir. 1964) (presumption of innocence; risk of prejudice from other-crimes evidence)
- Jones v. United States, 67 F.3d 320 (DC Cir. 1995) (prior crimes evidence prejudicial; limits on use in trials)
- Bishop v. United States, 983 A.2d 1029 (DC 2009) (collateral offenses should not be substantive proof of charged offense)
- Campbell v. United States, 450 A.2d 428 (DC 1982) (preservation of presumption of innocence; limits on mug-shot-type evidence)
- Martin v. United States, 127 F.2d 865 (DC Cir. 1942) (concurring views on admissibility of prior crimes)