Evidence Of Past Crimes Proper Under Bryant, 8th Circuit Rules

(July 7, 2016, 10:39 AM EDT) -- ST. PAUL, Minn. — Using the U.S. Supreme Court’s guidance from the recently decided United States of America v. Michael Bryant, Jr. (No. 15-420 [U.S. June 13, 2016]), the Eighth Circuit U.S. Court of Appeals on July 1 held that a trial court properly allowed testimony about a criminal defendant’s prior tribal court convictions and used the convictions as predicate offenses to sentence the defendant under federal law (United States of America v. Santana Drapeau, No. 14-3890, 8th Cir.; 2016 U.S. App. LEXIS 12131).

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