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United States v. Majeroni

United States District Court for the District of Maine
No. 2:13-cr-37-GZS (2013)


Facts

Timothy Majeroni (defendant) was charged with possession of child pornography based on pornographic materials found on his laptop computer. Prior to trial, the United States (plaintiff) moved to admit evidence that Majeroni had pleaded guilty to child-pornography possession in 2001. That prior guilty plea and subsequent conviction were also based on pornographic materials found on Majeroni’s laptop computer. The government moved to admit the evidence of Majeroni’s prior conviction under Federal Rule of Evidence 414, which provides that in criminal cases involving child molestation, the court may admit evidence that the defendant committed any other child molestation. Majeroni conceded that the 2001 conviction and the charges pending against him both involved child molestation as defined by Rule 414(d)(2). However, Majeroni argued that the evidence of his prior conviction was inadmissible under Federal Rule of Evidence 403 because its probative value was substantially outweighed by the risk of unfair prejudice. Specifically, Majeroni asserted that the 12-year time gap between his prior conviction and the pending charges made the evidence of the prior conviction unfairly prejudicial. Majeroni also argued that the government had substantial evidence besides the conviction that it could use to meet its burden of proof.

Rule of Law

Issue

Holding and Reasoning (Singal, J.)

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