United States v. Carroll
United States Court of Appeals for the Eighth Circuit
207 F.3d 465 (8th Cir. 2000)
Relevant factsFree
Gerald Carroll (defendant) was tried for a 1998 bank robbery, and the prosecution introduced his 1988 prior bank robbery conviction, in which he had similarly worn a stocking mask, jumped over the teller counter, and carried a gun; the district court admitted the prior conviction under Rule 404(b) for showing a "plan or pattern plus identity," and Carroll was convicted and appealed.
IssueFree
Whether a defendant's prior bank robbery conviction, occurring ten years earlier and sharing only generic robbery characteristics, is admissible to prove identity based on a distinctive modus operandi.