United States v. Stevens

Two white Air Force officers were robbed at gunpoint at Fort Dix (one also sexually assaulted) and identified Richard Stevens (defendant), who is Black, as the perpetrator. At trial, Stevens sought to introduce evidence of a similar robbery in which the victim, Tyrone Mitchell (also Black), said Stevens was not the robber, along with expert testimony that cross-racial identifications are less reliable and that Mitchell's same-race identification was therefore more trustworthy. Stevens also wanted to show police believed one person committed both robberies, since they shared distinctive characteristics and the stolen property from both ended up in the same location. The district court excluded all of this evidence, Stevens was convicted, and he appealed.