United States v. Van Metre
United States Court of Appeals for the Fourth Circuit
150 F.3d 339 (4th Cir. 1998)
James Van Metre (defendant) kidnapped Holly Ann Blake, sexually assaulted her, and strangled her to death, and was charged with kidnapping with intent to sexually assault under a federal statute. To help prove Van Metre's intent, the prosecution introduced testimony from Mary Yohe about Van Metre's conviction for kidnapping and sexually assaulting her just eleven days before the Blake incident. Van Metre sought to exclude the Yohe evidence under Federal Rules of Evidence 403 and 404(b), but the district court admitted it for the limited purpose of showing intent. Van Metre appealed, arguing the evidence was really used to attack his character and was unfairly prejudicial.
Whether evidence of a defendant's prior bad acts is admissible under Federal Rule of Evidence 404(b).