United States v. Gregory Hruby, 19 F.4th 963

Detective posed as a mother on social media after finding Hruby’s ad seeking an “open family” and engaged him in sexually explicit chats.
Hruby traveled from Texas to Kentucky and was arrested; after Miranda warnings he confessed to repeatedly molesting a friend’s daughter for several years and investigators found child pornography on his phone.
Federal indictment charged Hruby with two counts of crossing state lines with intent to engage in sexual acts with a child (18 U.S.C. § 2241(c)) and one count of possession of child pornography (18 U.S.C. § 2252(a)(4)(B)).
The government sought to admit under Fed. R. Evid. 414(a) Hruby’s messages and post-arrest confession as evidence of other child-molestation acts; the district court admitted them under Rule 104(b) conditional-relevance and declined to exclude under Rule 403.
A jury convicted Hruby on all counts; on appeal he argued (1) Rule 414(a) requires independent corroboration of a defendant’s confession before admission, and (2) the statements should have been excluded as unduly prejudicial under Rule 403.
The Sixth Circuit affirmed, rejecting a corroboration requirement and finding no abuse of discretion in the Rule 403 balancing given the similarity and probative value of the prior acts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 414(a) requires independent corroboration for a defendant’s confession of prior child molestation before admission under Rule 104(b)	Hruby: confession alone insufficient; Rule 414(a)/104(b) require independent corroboration	Government: Rule 414(a) admits relevant prior child-molestation evidence; Rule 104(b) preponderance standard suffices; no separate corroboration rule	No corroboration requirement; Rule 414(a) governed by Rule 104(b) relevance—confession may be admitted if a jury could reasonably find the prior act by a preponderance
Whether the admitted statements should have been excluded under Rule 403 as unduly prejudicial	Hruby: prior molestations were more egregious/dissimilar and risked conviction by retribution; highly prejudicial	Government: prior acts were sufficiently similar and highly probative of intent and plan; probative value outweighs unfair prejudice	Admission not an abuse of discretion—similarity and probative value outweighed prejudice under Rule 403

Huddleston v. United States, 485 U.S. 681 (1988) (establishes Rule 104(b) conditional-relevance preponderance standard for similar-act evidence)
United States v. LaVictor, 848 F.3d 428 (6th Cir. 2017) (declines to require corroboration for testimony admitted under Rule 413 and emphasizes Rule 104(b) flexibility)
United States v. Norris, 428 F.3d 907 (9th Cir. 2005) (holds Rule 414(a) does not require independent evidence of prior bad acts for admissibility)
United States v. Underwood, 859 F.3d 386 (6th Cir. 2017) (applies Rule 414 and Rule 403 balancing for admitting prior child-molestation evidence)
United States v. Brown, 617 F.3d 857 (6th Cir. 2010) (discusses corroboration rule preventing convictions solely on uncorroborated confession)
United States v. Libbey-Tipton, 948 F.3d 694 (6th Cir. 2020) (articulates broad district-court discretion in Rule 403 admissibility determinations)