Old Chief v. United States
Supreme Court of the United States · Decided January 7, 1997 · Core case
Full citation
Old Chief v. United States, 519 U.S. 172 (1997).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.This brief explains the opinion as issued. Later treatment and current-law status are not assessed here.
Old Chief
criminal defendantpetitioner
United States
prosecutionrespondent
Brief
Facts
In 1993, Old Chief was arrested after a fracas involving at least one gunshot. Federal prosecutors charged him with assault with a dangerous weapon, using a firearm in relation to a crime of violence, and possessing a firearm after a prior felony conviction under 18 U. S. C. §922(g)(1). Subject to certain limitations, the statute prohibits anyone convicted of a crime punishable by imprisonment for a term exceeding one year from possessing a firearm. The indictment identified Old Chief's prior crime as assault causing serious bodily injury. Before trial, Old Chief offered to stipulate that he had been convicted of a crime punishable by imprisonment exceeding one year. He asked the District Court to order the Government not to mention or offer evidence of the name or nature of his prior conviction. Old Chief argued that revealing his prior assault conviction would create unfair prejudice that substantially outweighed its probative value under Federal Rule of Evidence 403. The prosecutor refused to stipulate, insisting on his right to prove his case his own way. The District Court agreed, ruling that the prosecutor did not have to stipulate. At trial, over Old Chief's renewed objection, the Government introduced the judgment order from his prior conviction. The document disclosed that on December 18, 1988, Old Chief assaulted Rory Dean Fenner, causing serious bodily injury, and received a sentence of five years' imprisonment. The jury convicted Old Chief on all counts.
Issue
Does a district court abuse its discretion under Federal Rule of Evidence 403 by admitting the full record of a prior conviction solely to prove the prior-felon element of 18 U. S. C. §922(g)(1), when the defendant offers to concede the fact of that conviction and the name or nature of the offense risks unfair prejudice?
Holding
Because Old Chief offered to admit that he had been convicted of a qualifying felony under 18 U. S. C. §922(g)(1), and the Government offered the record of conviction solely to prove his felon status, the risk of unfair prejudice from revealing that his prior crime was assault causing serious bodily injury substantially outweighed the discounted probative value of the conviction record. The District Court abused its discretion in admitting the record, and the Ninth Circuit's judgment is reversed.
IRAC
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