United States v. Hall, 508 F. App'x 776

Hall was stopped for DUI on I-15 in Utah; four kilograms of cocaine were found in the spare tire of Hall’s 2008 Ford Explorer.
Hall and co-defendant Woods were indicted on a single count of possession with intent to distribute 500 g or more of cocaine.
Woods pled guilty and testified against Hall at trial; Woods’ prior drug dealings with Hall were referenced.
The government sought to admit prior interactions/deal as Rule 404(b) evidence; the district court deemed it inextricably intertwined with the charged offense.
Trial court allowed Woods to testify about the prior relationship; Hall was convicted after a two-day trial.
On appeal, Hall challenged the admission of the prior-interaction evidence as improper Rule 404(b) evidence; the circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prior interaction evidence was intrinsic to the charged crime or 404(b).	Hall argues the evidence is extrinsic under 404(b).	Hall contends the evidence is not intrinsic and should be excluded under 404(b).	Evidence was intrinsic; 404(b) did not apply.
If intrinsic, whether Rule 403 prejudice warrants exclusion.	Hall claims the evidence is disproportionately prejudicial.	Woods’ testimony was probative of relationship and knowledge.	District court did not err in balancing; prejudice did not overcome probative value.

U.S. v. Lambert, 995 F.2d 1006 (10th Cir. 1993) (intrinsic vs extrinsic; contextual background)
U.S. v. Parker, 553 F.3d 1309 (10th Cir. 2009) (intrinsic evidence framework for Rule 404(b))
U.S. v. Irving, 665 F.3d 1184 (10th Cir. 2011) (abuse of discretion for 404(b) analyses)
U.S. v. Richardson, 764 F.2d 1514 (5th Cir. 1985) (prior drug dealings as intrinsic background to charged crime)
U.S. v. Miranda, 248 F.3d 434 (5th Cir. 2001) (prior drug transaction between defendant and witness admissible for connection)
U.S. v. Tan, 254 F.3d 1204 (10th Cir. 2001) (unfair prejudice standard under Rule 403)