## Facts

- Jonathan Leigh Henslee, a state prisoner, alleged that Marty Singleton, a correctional officer, used excessive force by spraying him in the face with pepper spray.
- Henslee filed a federal civil-rights action asserting an Eighth Amendment excessive-force claim against Singleton.
- At the jury trial, the district court permitted Singleton to impeach Henslee with evidence of Henslee’s prior felony convictions under Federal Rule of Evidence 609(a)(1).
- The district court instructed the jury that it could consider the felony-conviction evidence only when evaluating Henslee’s credibility as a witness, not as evidence that Singleton was or was not liable.
- The jury returned a verdict for Singleton, and the district court entered judgment for the defense.
- Henslee appealed, challenging the admission of his felony convictions for impeachment.

## Issues

1. Did the district court abuse its discretion by admitting evidence of Henslee’s prior felony convictions under Federal Rule of Evidence 609(a)(1) to impeach his credibility in his civil excessive-force trial, where the court also gave a limiting instruction?

## Decision

- The appellate court affirmed the judgment for Singleton.
- The court held the district court did not abuse its discretion in admitting Henslee’s felony convictions for impeachment under Rule 609(a)(1), as limited by Rule 403.
- The court relied on the limiting instruction directing the jury to use the convictions only for credibility and applied the general presumption that jurors follow the court’s instructions.
- The court concluded Henslee failed to show that admitting the convictions resulted in unfair prejudice warranting a new trial.

## Legal Principles

- Under Federal Rule of Evidence 609(a)(1), evidence of a witness’s felony conviction may be admitted in a civil case to attack the witness’s character for truthfulness, subject to the balancing required by Rule 403.
- Rule 403 permits exclusion of otherwise admissible evidence if its probative value is substantially outweighed by a danger of unfair prejudice, confusion, or other listed harms.
- Appellate review of a district court’s evidentiary rulings is for abuse of discretion; reversal generally requires both error and a showing that the error affected the appellant’s substantial rights.
- A limiting instruction directing the jury to consider prior convictions only for credibility typically reduces the risk that the jury will misuse the evidence as proof of liability or propensity.

## Conclusion

In Henslee’s prisoner excessive-force suit, the appellate court affirmed the defense verdict because the district court acted within its discretion when it admitted Henslee’s prior felony convictions for impeachment under Rule 609(a)(1) and instructed the jury to consider those convictions only in assessing credibility, and Henslee did not demonstrate reversible prejudice from that ruling.


Henslee v. Singleton, 2018 WL 1252120 (2018)