519 U.S. 172 (1997) (Supreme Court of the United States)
Old Chief v. United States is a cornerstone evidence case for understanding how Federal Rule of Evidence 403 operates when the government seeks to prove a prior conviction as an element of an offense.
In a § 922(g)(1) prosecution, does a district court abuse its discretion under Federal Rule of Evidence 403 by admitting the name and nature of a defendant's prior felony conviction when the defendant offers to stipulate to the fact of a qualifying prior conviction?
Under Federal Rule of Evidence 403, courts must exclude relevant evidence if its probative value is substantially outweighed by a danger of unfair prejudice. In performing this balancing, courts must consider the availability of alternative evidence with the same probative value but lower risk of unfair prejudice. Where the sole relevance of a prior conviction is to prove the defendant's status as a felon (e.g., an element of 18 U.S.C. § 922(g)(1)), and the defendant offers to stipulate to that element, the government may be required to accept the stipulation; the name and nature of the prior offense must be excluded because their marginal probative value is substantially outweighed by the danger of unfair propensity prejudice.
Yes. It is an abuse of discretion under Rule 403 to admit the name and nature of the prior felony when the defendant offers to stipulate to the status element, because the stipulation provides equivalent probative value with far less risk of unfair prejudice.
Old Chief is a leading case on Rule 403 and the admissibility of prior convictions. It establishes that: (1) courts must consider evidentiary alternatives when balancing probative value against unfair prejudice; (2) in felon-in-possession prosecutions, a defendant's stipulation to status generally precludes admission of the name and nature of the prior felony; and (3) the prosecution's preference for narrative completeness does not override Rule 403 when the prior conviction bears only on a formal status element. For law students, the case illustrates the interaction between Rules 401, 403, and 404(b), and it provides a practical template for motions in limine to sanitize prior-conviction proof. It also clarifies the limits of the government's right to prove its case as it chooses, signaling that evidentiary discretion is bounded by prejudice considerations when equally probative alternatives exist.