Old Chief v. United States

In this case, Old Chief offered to stipulate to the fact of a prior conviction, which was an element of the crime with which he was charged.

At trial, he asked the court to order the prosecution to refrain from mentioning any fact surrounding the prior felony that made him a prohibited possessor of a firearm.

First, "an item of evidence might be viewed as an island," such that its probative value and danger for unfair prejudice would be assessed in a vacuum.

Second, the item of evidence in question could be measured in relation to "the full evidentiary context of the case as the court understands it when the ruling must be made."

Thus, the Court reasoned that an assessment of prejudice must be conducted with reference to all the other actually available evidence in the hands of the proffering party.

Yet, as far as the element of a prior conviction is concerned, a defendant's stipulation is just as conclusive as the underlying facts of the crime.

Justice O'Connor contested the majority opinion, which held that introducing the facts of a defendant's prior conviction could be unfairly prejudicial.

After all, Congress had made the fact of a prior conviction an element of the crime of being a felon in possession of a firearm.