United States v. Brian C. Sanders
663 F. App'x 781
| 11th Cir. | 2016Background
- Defendant Brian Sanders was convicted under 18 U.S.C. §§ 922(g)(1), 924(a)(2) for knowingly possessing a firearm after a felony conviction.
- Police responded to a report that Sanders threatened to shoot someone at a hair salon; an officer took a description and later heard a separate 911 call about a person with a firearm at a nearby car wash.
- Officer Samuel Holton went to the car wash, observed Sanders reach under a car, and after arrest found a loaded pistol next to the car where Sanders had bent down.
- The government introduced Holton’s testimony about the earlier hair-salon threat; Sanders objected, arguing that evidence of the uncharged salon incident was improper and prejudicial.
- The district court admitted the salon evidence; Sanders did not request a limiting instruction at trial.
- The Eleventh Circuit reviewed the evidentiary ruling for abuse of discretion and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of evidence about uncharged threats at hair salon | Gov: Evidence explains officer’s response and links discovery of gun to Sanders | Sanders: Salon threats are uncharged bad acts and impermissibly prejudicial | Evidence was intrinsic, admissible under Rule 403 balancing; no abuse of discretion |
| Need for limiting instruction | Gov: N/A | Sanders: Failure to give limiting instruction prejudiced jury | No error: limiting instruction only required if requested; Sanders did not request one |
Key Cases Cited
- United States v. Fortenberry, 971 F.2d 717 (11th Cir. 1992) (standards for admissibility of uncharged conduct and 404(b) analysis)
- United States v. Cohen, 888 F.2d 770 (11th Cir. 1989) (404(b) governs extrinsic evidence of prior bad acts)
- United States v. US Infrastructure, Inc., 576 F.3d 1195 (11th Cir. 2009) (when uncharged conduct is intrinsic and completes the story)
- United States v. Wright, 392 F.3d 1269 (11th Cir. 2004) (uncharged-conduct admissible to provide context and sequence of events)
- United States v. Smith, 459 F.3d 1276 (11th Cir. 2006) (Rule 403 exclusion is narrow; limiting instruction rules)
- United States v. Edouard, 485 F.3d 1324 (11th Cir. 2007) (relevant evidence is inherently prejudicial; Rule 403 excludes only when unfair prejudice substantially outweighs probative value)
- United States v. Barner, 441 F.3d 1310 (11th Cir. 2006) (abuse of discretion standard for evidentiary rulings)
- United States v. Khan, 794 F.3d 1288 (11th Cir. 2015) (scope of appellate review for district-court discretion)