United States v. Jackson
United States District Court for the Eastern District of New York
405 F. Supp. 938 (E.D.N.Y. 1975)
After a New York bank robbery that weak video and eyewitness evidence failed to conclusively link to any suspect, Jackson (defendant) was later arrested in Georgia using a false identification during an unrelated traffic stop, where guns were also found in his car; he subsequently escaped from the Georgia jail and was separately under indictment in New York for an unrelated assault. The prosecution wanted to introduce his presence in Georgia under a false name as evidence of flight showing a guilty conscience about the robbery, but doing so risked exposing the jury to the unrelated Georgia arrest, the guns found in the car, his jail escape, and the separate assault indictment. Jackson moved before trial to exclude the false-name evidence.
Whether a court may address the problem of highly probative but highly prejudicial flight evidence by permitting the parties to stipulate to the underlying facts rather than presenting the full prejudicial details to the jury.