United States v. Curtis Adams, 783 F.3d 1145

Adams was convicted of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
The government sought to admit Adams’s prior firearm offenses under Rule 404(b) to show knowledge and intent.
Prior convictions admitted: a 2008 federal felon-in-possession and a 2005 state conviction for unlawful use of a weapon (carrying a concealed weapon).
On May 28, 2013, detectives observed Adams near a presumptive drug transaction scene, he fled while brandishing a semi-automatic pistol, and a firearm was recovered after he dropped it.
The district court weighed Rule 404(b) factors, acknowledged potential unfair prejudice, yet admitted the evidence and gave limiting instructions on its use.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 404(b) evidence was properly admitted.	Adams contends the court abused its discretion given the evidence’s prejudicial nature.	Adams argues the evidence is admissible as 404(b) knowledge/intent.	Admissible under 404(b) with harmless-error review.
Was any error harmless given other eyewitness testimony and instructions?	Adams asserts the error affected the verdict by distracting jurors.	The jury heard multiple witnesses supporting possession and admissions.	Harmless error; jury likely considered limiting instructions and other testimony.
Do prior firearm convictions properly prove knowledge and intent under circuit precedent?	Adams challenges continued use of prior gun offenses to prove knowledge/intent.	The district court relied on established Eighth Circuit precedent.	Yes; prior firearm convictions may prove knowledge and intent in such cases.

United States v. Stroud, 673 F.3d 854 (8th Cir. 2012) (prior firearms offenses address knowledge and intent)
United States v. Halk, 634 F.3d 482 (8th Cir. 2011) (prior firearms offenses probative of knowledge/intent)
United States v. Oaks, 606 F.3d 530 (8th Cir. 2010) (prior conviction for armed robbery addresses knowledge/intent)
United States v. Walker, 470 F.3d 1271 (8th Cir. 2006) (interpretation of 404(b) and intent concepts)
United States v. Washburn, 728 F.3d 775 (8th Cir. 2013) (unfair prejudice did not override probative value)