Relevance and Sources for Exclusion under Evidence Law
Relevance and Sources for Exclusion under Evidence Law
I. Relevance – Basic Concept
Relevance is the foundational principle in evidence law that governs what evidence can be admitted in court.
Relevant evidence is defined as evidence that makes a fact more or less probable than it would be without the evidence.
The fact must be of consequence to the determination of the action.
Federal Rules of Evidence (FRE) – Rule 401
"Evidence is relevant if:
(a) it has any tendency to make a fact more or less probable than it would be without the evidence; and
(b) the fact is of consequence in determining the action."*
II. Sources for Exclusion of Evidence Despite Relevance
Even relevant evidence may be excluded if its probative value is substantially outweighed by other considerations such as:
Unfair prejudice
Confusion of the issues
Misleading the jury
Undue delay
Waste of time
Unduly cumulative
This is governed by Rule 403 of the Federal Rules of Evidence.
III. Important Case Law on Relevance and Exclusion
1. Old Chief v. United States, 519 U.S. 172 (1997)
Facts:
Defendant charged with felon in possession of a firearm.
The prosecution wanted to introduce evidence of the defendant’s prior felony conviction.
The defendant offered to stipulate to the prior conviction to avoid prejudicial details.
Issue:
Should the court admit the full details of the prior conviction, or accept the defendant’s stipulation?
Holding:
The Supreme Court ruled that when a defendant offers to stipulate to a fact that the prosecution seeks to prove with more prejudicial evidence, the court should generally accept the stipulation.
The probative value of the detailed prior conviction evidence was substantially outweighed by unfair prejudice.
Importance:
Established a clear example of Rule 403 exclusion balancing.
Courts must consider less prejudicial alternatives, like stipulations.
2. Huddleston v. United States, 485 U.S. 681 (1988)
Facts:
The government introduced evidence of prior similar acts to prove a pattern of behavior.
Defendant objected as the evidence was irrelevant and prejudicial.
Issue:
Can evidence of prior bad acts be admitted to show a pattern or intent?
Holding:
The Court held that evidence of prior acts is relevant if it helps prove material issues (like intent or knowledge) other than character.
However, such evidence must satisfy Rule 403 balancing and be properly supported by evidence.
Importance:
Clarified the standards for admitting “other acts” evidence under Rule 404(b).
Emphasized relevance and careful balancing with potential prejudice.
3. Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993)
Facts:
Plaintiff presented expert scientific testimony about birth defects allegedly caused by a drug.
The defendant challenged the reliability and relevance of the expert testimony.
Issue:
How should courts determine the relevance and reliability of scientific evidence?
Holding:
The Supreme Court held that trial judges must act as gatekeepers to ensure that scientific evidence is both relevant and reliable.
Relevance requires that the evidence logically advance the case.
Reliability involves factors like testability, peer review, error rates.
Importance:
Daubert established the relevance and reliability framework for expert testimony.
This case highlighted the exclusion of evidence even if relevant, based on reliability.
4. Michelson v. United States, 335 U.S. 469 (1948)
Facts:
Defendant was convicted of illegal possession of alcohol.
The prosecution sought to introduce evidence of prior criminal conduct to show credibility.
Issue:
When is evidence of prior bad acts admissible to impeach a witness?
Holding:
The Court held that evidence of prior acts for impeachment must be relevant and its probative value must outweigh unfair prejudice.
Prior acts that do not directly relate to truthfulness are often excluded.
Importance:
Reinforces the balance between relevance and exclusion.
Sets limits on impeachment evidence.
5. United States v. Abel, 469 U.S. 45 (1984)
Facts:
Defendant was African American and sought to introduce evidence of racial bias against him in jury selection.
Government objected, claiming the evidence was irrelevant.
Issue:
Can evidence of racial bias in jury selection be admitted?
Holding:
The Supreme Court ruled that such evidence is relevant to show discriminatory intent and must be admitted.
This evidence is not excluded even if potentially prejudicial because it goes directly to a constitutional issue.
Importance:
Demonstrates that relevance can override usual exclusion when constitutional rights are implicated.
IV. Summary Table
| Case | Key Issue | Holding | Importance |
|---|---|---|---|
| Old Chief v. U.S. | Prior conviction evidence | Accept stipulations to avoid unfair prejudice | Rule 403 balancing |
| Huddleston v. U.S. | Prior acts for intent | Admissible if relevant and supported | Rule 404(b) application |
| Daubert v. Merrell Dow | Expert testimony relevance | Judge as gatekeeper for relevance and reliability | Relevance + reliability gatekeeping |
| Michelson v. U.S. | Impeachment with prior acts | Must balance probative value vs prejudice | Limits on impeachment evidence |
| United States v. Abel | Evidence of racial bias | Relevant and must be admitted | Relevance for constitutional issues |
V. Conclusion
Relevance is necessary but not sufficient for admissibility.
Even relevant evidence can be excluded under Rule 403 to avoid unfair prejudice or confusion.
Courts conduct a careful balancing act to ensure fairness.
Certain evidence, like expert testimony or constitutional issues, requires additional scrutiny regarding relevance and exclusion.
The cases above illustrate these principles clearly in various contexts.
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