Brief Fact Summary. Alfred Trenkler (Appellant) was convicted by a jury of various charges, all related to the explosion of a bomb in Massachusetts. Appellant appeals here, challenging the lower court’s decision to allow evidence related to Appellant’s involvement in a prior bombing to be admitted at Appellant’s trial.
Synopsis of Rule of Law. Evidence is admissible under Federal Rule of Evidence 404(b) only when the evidence is determined to have some “special relevance,” independent of its tendency to show criminal propensity, on a material issue, unless the probative value of the evidence is substantially outweighed by the danger of unfair prejudice.
Issues.
Did the lower court error by allowing evidence of the 1986 Quincy bombing, including the EXIS database-derived evidence, to be admitted at Appellant’s trial?
Held.
No; under Federal Rule of Evidence 404(b), evidence is admissible when there exists some “special relevance,” independent of its tendency to show criminal propensity, on a material issue and when the probative value of the evidence is not substantially outweighed by the danger of unfair prejudice; here, there was such a special relevance with respect to the evidence and a reasonable jury could have determined that the same person was responsible for both bombs, and