State v. McAllister

451 N.W.2d 764, 153 Wis. 2d 523, 1989 Wisc. App. LEXIS 1152
CourtCourt of Appeals of Wisconsin
DecidedNovember 15, 1989
Docket88-1364-CR
StatusPublished
Cited by11 cases

This text of 451 N.W.2d 764 (State v. McAllister) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. McAllister, 451 N.W.2d 764, 153 Wis. 2d 523, 1989 Wisc. App. LEXIS 1152 (Wis. Ct. App. 1989).

Opinions

SUNDBY, J.

David McAllister appeals from a judgment convicting him of possession of a firearm as a felon, contrary to sec. 941.29, Stats.1 McAllister claims that because he was willing to stipulate that he was a convicted felon, the trial court abused its discretion in admitting evidence of the nature of his prior felony conviction.

We conclude that where prior conviction of a felony is an element of the offense with which the defendant is charged and the defendant is willing to stipulate that he or she is a convicted felon, evidence of the nature of the felony is irrelevant if offered solely to establish the felony-conviction element of the offense. The trial court therefore abused its discretion in allowing the prosecutor to inform the jury as to the nature of McAllister's crime. We conclude, however, that the error was harmless and affirm the judgment.

[526]*526HH

BACKGROUND

The state rejected McAllister's offer to stipulate that he had been convicted of a felony. The trial court received in evidence a certified copy of McAllister's robbery conviction. Over McAllister's objection, the trial court allowed the prosecutor to advise the jury that the judgment of conviction showed that McAllister had been convicted of the felony offense of robbery. The exhibit, however, did not go to the jury and the jury was not advised of the aggravated circumstances of the robbery or that McAllister was a repeat offender.

HH HH

ADMISSIBILITY OF EVIDENCE TO ESTABLISH FELONY — CONVICTION ELEMENT

(1) Robbery Conviction as Other Crimes Evidence. The state argues that McAllister's previous conviction was not evidence of other misconduct under sec. 904.04(2), Stats. Rather, it was conduct which formed an essential element of the crime charged. State v. Aldazabal, 146 Wis. 2d 267, 269, 430 N.W.2d 614, 616 (Ct. App. 1988). This distinction has not been drawn by the Wisconsin Supreme Court.

Admission of evidence that McAllister had been convicted of robbery had the danger of permitting the jury to convict him based on the inference that if he committed a robbery once, he was likely to have done so again. This is precisely the kind of evidence sec. 904.04(2), Stats., is intended to exclude. See State v. [527]*527Rutchik, 116 Wis. 2d 61, 67-68, 341 N.W.2d 639, 642 (1984).

The admissibility of evidence that McAllister previously had been convicted of robbery was not exempt from the two-step analysis required under secs. 904.04(2) and 904.03, Stats., see State v. Evers, 139 Wis. 2d 424, 434, 407 N.W.2d 256, 261 (1987), simply because conviction of a felony was an element of the crime with which he was charged.

(2) State's Refusal to Stipulate. The trial court ruled that it could not compel the state to accept McAl-lister's stipulation. As a general proposition, "a party is not required to accept a judicial admission of his adversary, but may insist on proving the fact." United States v. Allen, 798 F.2d 985, 1001 (7th Cir. 1986), (quoting Parr v. United States, 255 F.2d 86, 89 (5th Cir.), cert. denied, 358 U.S. 824 (1958)). The principle is that "[a] cold stipulation can deprive a party 'of the legitimate moral force of his evidence,' 9 Wigmore on Evidence, sec. 2591 at 589 [(3rd ed. 1940)], and can never fully substitute for tangible, physical evidence or the testimony of witnesses." Allen, 798 F.2d at 1001 (quoting United States v. Grassi, 602 F.2d 1192, 1197 (5th Cir. 1979), vacated on other grounds, 448 U.S. 902 (1980)).

We have found no Wisconsin case in point. A number of federal courts, however, have considered whether the government is required to accept a stipulation as to other-crimes evidence under Fed. R. Evid. 404(b), which is virtually identical to sec. 904.04(2), Stats.2

[528]*528Several federal courts have refused to require the Government to accept the defendant's stipulation or admission of a prior crime where the prior crime tended to show intent, motive, plan, etc. See, e.g., United States v. DeJohn, 638 F.2d 1048 (7th Cir. 1981) (opportunity); United States v. Doherty, 675 F. Supp. 714 (D. Mass. 1987) (opportunity, intent, plan, preparation, and method); United States v. Chaimson, 760 F.2d 798 (7th Cir. 1985) (intent and preexisting scheme, design or plan); United States v. Williford, 764 F.2d 1493 (11th Cir. 1985) (intent).

Other federal courts, however, have admitted evidence of the nature of the crime, where the evidence was introduced solely to prove the felony-conviction element of the crime with which the defendant was charged. See, e.g., United States v. Blade, 811 F.2d 461 (8th Cir.), cert. denied, 484 U.S. 839 (1987) (in a prosecution for possessing firearm as a convicted felon, the Government was not required to accept defendant's stipulation in lieu of proof of that conviction); Rush v. United States, 795 F.2d 638 (8th Cir. 1986) (same); United States v. Booker, 706 F.2d 860 (8th Cir.), cert. denied, 464 U.S. 917 (1983) (same); United States v. Williams, 612 F.2d 735 (3rd Cir. 1979), cert. denied, 445 U.S. 934 (1980) (no authority for counsel or the court to modify a criminal statute by eliminating through stipulation one of the elements of the crime).

Other federal courts have held that where the defendant offers to stipulate or admit to the felony-conviction element of the crime with which he or she is charged, the trial court may abuse its discretion if it admits evidence of the nature of the prior felony conviction. See, e.g., United States v. Spletzer, 535 F.2d 950, 955-56 (5th Cir. 1976) (probative value of nature of conviction substantially outweighed by its danger of creating prejudice); [529]*529United, States v. O'Shea, 724 F.2d 1514, 1516 (11th Cir. 1984) (where a prior conviction is part of an offense and the defendant offers to stipulate to the prior conviction, it may constitute an abuse of discretion to allow the nature of the offense to be admitted).

(3) Relevancy.

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451 N.W.2d 764 (Court of Appeals of Wisconsin, 1989)

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Bluebook (online)
451 N.W.2d 764, 153 Wis. 2d 523, 1989 Wisc. App. LEXIS 1152, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcallister-wisctapp-1989.