United States v. Akeem Caldwell
760 F.3d 267
| 3rd Cir. | 2014Background
- Caldwell was convicted of being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
- Detectives observed Caldwell allegedly remove a gun from his waistband and place it behind Tigney’s back during a nighttime stop.
- Tigney provided a false name at the scene; detectives released him after concluding he had no prior criminal record.
- Tigney later confessed to Caldwell’s defense investigators that the firearm belonged to him, not Caldwell, but asserted Fifth Amendment rights at trial.
- Caldwell’s defense sought to admit Tigney’s out-of-court admission as a statement against interest under Rule 804(b)(3).
- Two trials occurred: a mistrial followed by a second trial in which Caldwell was convicted; the district court admitted Caldwell’s prior firearm convictions during cross-examination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Caldwell's prior firearm convictions were admissible under Rule 404(b). | Caldwell | Government | Not admissible; improper purpose |
| Whether Caldwell’s knowledge was at issue to satisfy 404(b)’s non-propensity purpose. | Caldwell | Government | Knowledge not at issue; inadmissible for 404(b) |
| Whether the district court properly balanced probative value against prejudice under Rule 403. | Caldwell | Government | Rule 403 balancing was insufficient or inadequately on the record |
| Whether the prior convictions were admissible as impeachment evidence under Rule 609(a)(1)(B). | Caldwell | Government | Not admissible; Rule 609 not satisfied |
| Whether Tigney’s out-of-court confession to defense counsel could be admitted under Rule 804(b)(3). | Caldwell | Government | Exclusion proper; not sufficiently trustworthy |
Key Cases Cited
- Michelson v. United States, 335 U.S. 469 (1948) (relevance of prior bad character to probability of guilt)
- Sampson, 980 F.2d 883 (3d Cir. 1992) (proper purposes for Rule 404(b); chain of inferences required)
- Davis, 726 F.3d 434 (3d Cir. 2013) (four-step 404(b) analysis; burden to identify proper purpose)
- Lee, 612 F.3d 170 (3d Cir. 2010) (knowledge/intent not proper 404(b) in actual possession cases)
- Linares, 367 F.3d 941 (D.C. Cir. 2004) (prior unlawful firearm possession not admissible when possession is at issue)
- Jones, 484 F.3d 783 (5th Cir. 2007) (knowledge not proper 404(b) where theory is actual possession)
- Huddleston, 485 U.S. 681 (1988) (framework for Rule 404(b) admissibility)
- Green, 617 F.3d 233 (3d Cir. 2010) (review of evidentiary rulings; standard of abuse of discretion; legal interpretation)
- Smith, 725 F.3d 340 (3d Cir. 2013) (necessity of articulating non-propensity chain; Rule 403 balancing on record)