United States v. Scott Michael Patrick, 513 F. App'x 882

Patrick, an inmate at Coleman F.C.C., is charged with Aiding and Abetting an Assault Resulting in Serious Bodily Injury under 18 U.S.C. §§ 113(a)(6), (b)(2), and 2;Malloy and Thompson are co-participants in the fight.
Two surveillance videos—close-up (highly focused on the stabbing) and wide-angle (distant view)—captured portions of the assault.
Patrick moved to exclude both videos under Rule 403 as unfairly prejudicial and not probative of his role.
District court granted the motion to exclude the close-up video but allowed that Moghdam’s stabbing could be established by eyewitnesses; it also excluded the wide-angle video.
On appeal, the government contends the district court abused its discretion by excluding highly probative video evidence; Patrick argues the videos are irrelevant or substantially prejudicial.
The Eleventh Circuit vacates and remands, holding the district court abused Rule 403 balancing and that the videos are relevant and probative.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused Rule 403 balancing	Patrick: videos are irrelevant or unfairly prejudicial	Government: videos are highly probative and not unfairly prejudicial	Yes, district court abused Rule 403 balancing
Whether the videos are relevant to Patrick’s role and proximate causation	Patrick concedes stabbing occurred and his role is minimal	Videos depict the events and help prove involvement and proximate cause	Yes, videos are relevant and probative on Patrick’s role and causation
Whether partial portions of the fight rendered the videos unduly prejudicial	Incomplete depictions mislead the jury	Partial view is not inherently prejudicial; probative value remains	No, not substantially prejudicial; admissible with proper context

Old Chief v. United States, 519 U.S. 172 (U.S. 1997) (relevance and prejudice balancing; defense stipulations do not render evidence irrelevant)
United States v. King, 713 F.2d 627 (11th Cir. 1983) (Rule 403 balancing; court’s discretion in limine is narrow but principled)
United States v. Lopez, 649 F.3d 1222 (11th Cir. 2011) (evidence should be admitted if probative value outweighs prejudice; sparing use of Rule 403)
United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (district court’s first-hand evaluative role in evidentiary matters reviewable on appeal)
United States v. De Parias, 805 F.2d 1447 (11th Cir. 1986) (graphic evidence challenged but upheld when not inherently prejudicial)
Old Chief v. United States, (already cited) (as above) (see above)