United States v. Miller (2012)
United States Court of Appeals for the Seventh Circuit
673 F.3d 688 (2012)
Shariff Miller (defendant), convicted in 2000 of possessing cocaine with intent to distribute, was charged in 2008 after police found a large quantity of cocaine in his room, both with possessing cocaine with intent to distribute and with being a felon in possession of firearms; Miller denied the cocaine was his but never denied it was intended for distribution. The government introduced his 2000 conviction to show intent for the 2008 charges, and the jury convicted him on both counts.
Whether, under Federal Rule of Evidence 404(b), evidence of a criminal defendant's prior bad acts is admissible to show the defendant's criminal intent only if intent is an element of the crime charged and at issue in the case.