## Facts

- Johnny Lynn Old Chief was charged with, among other offenses, possessing a firearm after a felony conviction in violation of 18 U.S.C. § 922(g)(1).
- The government sought to prove the prior-conviction element by introducing the judgment record showing a prior conviction for “assault causing serious bodily injury.”
- Old Chief offered to stipulate that he had been convicted of a crime punishable by imprisonment for more than one year and moved to exclude the name and nature of the prior offense under Federal Rule of Evidence 403.
- The government refused the stipulation and insisted on introducing the judgment record.
- The district court admitted the judgment record over objection, and the jury convicted Old Chief on the § 922(g)(1) count.
- The Ninth Circuit affirmed, reasoning the government could prove the element with its chosen evidence despite the stipulation offer.

## Issues

1. Whether, under Federal Rule of Evidence 403, a district court abuses its discretion by admitting the name and nature of a defendant’s prior conviction to prove the prior-conviction element of § 922(g)(1) after the defendant offers to stipulate to that element.

## Decision

- The Supreme Court reversed (5–4) in an opinion by Justice Souter.
- The Court held the district court abused its discretion under Rule 403 by admitting the full judgment record identifying the prior offense when Old Chief offered a concession establishing the element.
- The Court remanded for further proceedings consistent with its opinion.

## Legal Principles

- Evidence of a prior conviction’s name and nature may be relevant under Rule 401 to the prior-conviction element, but relevance does not resolve admissibility when Rule 403 applies.
- “Unfair prejudice” under Rule 403 includes the risk that jurors will convict for reasons other than proof of the charged offense, including propensity reasoning from a prior bad act.
- Rule 403 balancing must account for actually available evidentiary alternatives; when a less prejudicial substitute proves the same point, the probative value of the more prejudicial item is reduced for Rule 403 purposes.
- In a § 922(g)(1) prosecution, when the prior conviction is offered solely to prove felon status and the defendant offers to concede that status, admitting the name/nature of the prior offense is improper if it adds little legitimate probative value and carries a substantial risk of unfair prejudice.
- The prosecution’s general ability to present its case with evidence of its own choosing is limited by Rule 403 when a minimally prejudicial alternative establishes the element equally well.

## Conclusion

The Court required exclusion under Rule 403 of the prior conviction’s name and nature in a § 922(g)(1) case when a defendant’s stipulation fully proves the status element and the detailed record creates a substantial risk that the jury will reason from past misconduct rather than evidence of the charged firearm offense.


Old Chief v. United States, 519 U.S. 172 (1997)