## Facts

- The FBI ran an undercover business in southern Missouri that bought salvaged wrecked cars and sold their public VIN tags, anticipating some buyers would use the tags to “retag” stolen vehicles for resale.
- Eddie Williams was implicated in a theft–retagging–resale scheme involving four automobiles stolen in the St. Louis area and later delivered to buyers in Illinois in 1981 or early 1982.
- Four purchasers testified they bought automobiles from Williams and took delivery from him in Illinois.
- Each delivered vehicle contained a VIN tag traceable to the FBI operation and associated with suspected stolen-vehicle dealers L.C. Kirkwood and Lee Morgan.
- The government’s theory was that Williams served as a middleman between Kirkwood/Morgan and end purchasers and knowingly transported stolen vehicles in interstate commerce.
- Williams admitted he acted as a delivery person for Kirkwood and Morgan but denied knowing the vehicles were stolen; his knowledge and credibility were the central disputed matters at trial.
- At trial, the government elicited testimony that Williams’s nickname was “Fast Eddie” and pursued impeachment tactics later challenged on appeal.
- A jury convicted Williams of four counts under 18 U.S.C. § 2312 and aiding and abetting under 18 U.S.C. § 2; he received a total sentence of six years.

## Issues

1. Whether admitting and emphasizing the nickname “Fast Eddie” improperly invited a character/propensity inference and unfairly prejudiced the jury where knowledge was the key issue.
2. Whether the government employed improper impeachment or trial tactics that exceeded permissible credibility testing.
3. Whether the cumulative effect of these errors, in a close case turning on mens rea and credibility, deprived Williams of a fair trial requiring reversal.

## Decision

- The Seventh Circuit vacated the convictions and remanded for a new trial.
- The court held that the case was close because the only real dispute was whether Williams knew the cars were stolen.
- The court found reversible error in the use of “Fast Eddie” because it carried a pejorative connotation and was not shown to be necessary for a legitimate evidentiary purpose that outweighed prejudice.
- The court also identified a separate, significant error involving the government’s impeachment practices.
- Considering the errors together, the court concluded they were not harmless and undermined confidence in the verdict.

## Legal Principles

- In a prosecution where intent or knowledge is the dispositive issue and the proof is not overwhelming, improperly prejudicial evidence and prosecutorial tactics are more likely to affect the verdict.
- Nicknames with negative connotations may function as impermissible character evidence when used to suggest a defendant’s criminal disposition rather than to prove a material fact.
- Appellate review may assess the cumulative effect of multiple trial errors; individually arguable missteps can collectively deprive a defendant of a fair trial.
- When the cumulative impact of errors is prejudicial in context, the appropriate remedy is vacatur and remand for a new trial rather than affirmance on harmless-error grounds.

## Conclusion

Because Williams’s knowledge that the vehicles were stolen was the sole contested element and the trial turned largely on credibility, the admission and emphasis of the “Fast Eddie” nickname and improper impeachment tactics, viewed cumulatively, denied him a fair trial; the convictions were vacated and the case was remanded for retrial.


United States v. Williams, 739 F.2d 297 (7th Cir. 1984)