United States v. Samson K. Lloyd

A jury found Samson Lloyd guilty on two counts of being a convicted felon in possession of a firearm and ammunition in violation of 18 U.S.C. § 922 (g)(1). Lloyd claims the district court erred «in allowing the prosecution to prove three prior felony convictions when only one was necessary. We affirm.

I.

To establish a violation of 18 U.S.C. § 922 (g)(1), the prosecution was required to prove beyond a reasonable doubt that Lloyd had been convicted “of a crime punishable by imprisonment for a term exceeding one year.” Lloyd declined to stipulate he was a convicted felon. The prosecution then requested permission to prove several of Lloyd’s eight prior felony convictions to protect itself against successful challenges to evidence of particular convictions. The court allowed the prosecution to introduce evidence of three prior convictions because “[w]e don’t know what the defense is until after [the prosecution] has rested [its] case.” Lloyd renewed his objection when evidence of the convictions was offered, and sought by cross-examination to question the clarity of fingerprints relied upon to connect Lloyd with the convictions.

II.

If Lloyd had stipulated to being a convicted…