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United States v. Gulley
United States Court of Appeals for the Fifth Circuit
526 F.3d 809 (2008)
Arzell Gulley (defendant) was charged with murdering fellow inmate, Daryl Brown, while both were incarcerated in federal prison. Prior to trial, the government (plaintiff) filed a motion in limine and argued that evidence of Brown’s prior acts of violence should be excluded. In his response, Gulley argued that the court should admit evidence showing that on the day of Brown’s death, Brown made threats to other inmates, sought to obtain weapons, and carried a knife immediately before the altercation. The trial-court judge granted most of the motion in limine based on the fact that Gulley did not have actual knowledge of the acts alleged. At trial, Gulley could introduce as prior-acts evidence only that Brown had a knife before the altercation, as well as reputation and opinion testimony of Brown’s character. Gulley was convicted at trial. On appeal, Gulley argued that the evidence of Brown’s prior specific acts should have been admitted because it was necessary to prove the essential element that Brown was the first aggressor in Gulley’s self-defense claim.
Rule of Law
Holding and Reasoning (Per curiam)
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