United States v. Jason Carter
779 F.3d 623
6th Cir.2015Background
- Amanda Steadman’s meth cook exploded in her apartment, causing severe injuries and fire; Jason Carter was present and fled the scene.
- James Steadman admitted to meth cooking; he was decontaminated and later sheltered at Haven of Rest; Carter had ties to Haven of Rest.
- Federal charges were conspiracy to manufacture meth, possession of precursors, and creation of a substantial risk of harm; James and Amanda pled to testify for the government.
- Carter was tried; the government moved to admit Rule 404(b) evidence that Carter previously distributed Suboxone at Haven of Rest to show intent.
- The district court allowed the 404(b) evidence; Carter was convicted on all counts and sentenced to 97 months plus restitution.
- On appeal, Carter challenged the admissibility of the 404(b) evidence, arguing it was not probative of specific intent and unfairly prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 404(b) evidence of prior drug distribution was admissible to prove specific intent. | Carter intended to join the conspiracy; prior distribution is probative of intent. | Prior distribution of a different drug and different scheme is not sufficiently similar to manufacturing meth to prove specific intent. | Admission of 404(b) evidence was improper; probative value was not substantially outweighed by prejudice. |
Key Cases Cited
- United States v. De Oleo, 697 F.3d 338 (6th Cir. 2012) (three-step test for 404(b) admissibility)
- United States v. Johnson, 27 F.3d 1186 (6th Cir. 1994) (specific-intent purpose of 404(b) evidence)
- United States v. Haywood, 280 F.3d 715 (6th Cir. 2002) (similarity and temporal proximity required for relevance to intent)
- United States v. Bilderbeck, 163 F.3d 971 (6th Cir. 1999) (distinguishes admissibility of 404(b) evidence in different contexts; stipulation caveats)
- United States v. Bell, 516 F.3d 432 (6th Cir. 2008) (mere possession is not sufficiently similar to distribution for 404(b) probative value)
- Old Chief v. United States, 519 U.S. 172 (U.S. 1997) (prosecution may prove its case without stipulation regarding elements)