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United States v. Estes

994 F.2d 147 (1993)

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United States v. Estes

United States Court of Appeals for the Fifth Circuit

994 F.2d 147 (1993)

Facts

Douglas Yeager, a police officer, stopped Ralph Edward Estes (defendant) for a traffic violation. Yeager discovered a firearm in the vehicle. Subsequently, Estes was charged with unlawful possession of a firearm. At Estes’s trial, the government (plaintiff) called Yeager as a witness. Yeager had a prior criminal conviction for impersonating a public official. The prior conviction was approximately 12 years old. The government filed a motion in limine, seeking to exclude evidence of Yeager’s prior conviction. The district-court judge granted the motion in limine, excluding Yeager’s prior conviction pursuant to Federal Rule of Evidence 609(b). Yet the judge failed to conduct Rule 609(b)’s balancing test on the record. Thus, the trial record did not contain the balancing-test analysis of Yeager’s prior conviction. Yeager testified at Estes’s trial, and Estes was convicted. Estes appealed.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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