United States v. Farish

MELLOY, Circuit Judge,

concurring.

I believe the domestic violence evidence in this case was improperly admitted under Federal Rule of Evidence 404(b). I conclude the link between the contested evidence and Farish’s “motive” is extremely tenuous and that any probative value is substantially outweighed by its unfair prejudicial effect. However, because I believe the other evidence against Farish was quite strong and that admission of the improper evidence was harmless error, I concur.

The government argues that the domestic abuse evidence demonstrates Farish’s motive to target Susan Metzger for the arson. This argument would be much stronger if Metzger, and not Monica Leinen, had been the victim of the domestic abuse. See United States v. Walker, 428 F.3d 1165, 1170 (8th Cir.2005) (approving the admission of evidence of prior threats as relevant to prove motive and intent in prosecution for threats against the same victim). However, here, the linkage is much more tenuous. Under the government’s theory, the fact that Farish had domestically abused Leinen shows why he would conclude the woman who had taken Leinen in after the abuse would be the one who keyed his car, thereby providing a motive for retaliation against Metzger through arson. I find this logic strained, at best. First, the evidence was substantial that Metzger had given shelter to Leinen, because Leinen needed a place to stay after she and Farish had gotten into a number of arguments. The domestic abuse is only one part of the deterioration of the relationship between Farish and Leinen. The very specific evidence about the abuse Leinen suffered at Farish’s hands was unnecessary to document the deterioration of the relationship or Met-ger’s role in providing support for Leinen.

Secondly, I find the logic that Farish’s domestic abuse against Leinen somehow explains his conclusion that Metzger was the one who keyed his car unpersuasive. The passage of time between Leinen’s stay with Metzger and Farish’s car getting keyed undermines this linkage; Farish’s car was keyed in November 2002, and Leinen last stayed with Metger in April 2001. Cf. United States v. Bettelyoun, 892 F.2d 744, 747 n. 1 (8th Cir.1989) (finding, in the alternative, that an assault on the mother of the defendant’s child was relevant to prove motive or plan in prosecution for killing the defendant’s current lover when the assault was one hour prior to the killing). While we have approved far longer time periods between bad acts and charged offenses, see, e.g., Walker, 428 F.3d at 1170 (noting that bad acts up to thirteen years before the charged crime have been found to be admissible under Rule 404(b)), in the end, whether a prior bad act is sufficiently close in time to have probative value “is a question of reasonableness under all the circumstances.” Id. Because the linkage between the domestic abuse of Leinen and the arson committed against Metzger is already strained, the passage of time between the two events further undermines any potential probative value. Moreover, even if one accepts the linkage between Metzger’s role in the aftermath of the abuse as providing mo*828tive, one can easily imagine how the evidence about Metzger’s support of Leinen, and even her rule about not allowing contact with Farish at her home, could be admitted to show motive without including the facts of the abuse.

Finally, even if one assumes that there is some tenuous argument that through several steps of logic we can get from Farish’s domestic abuse of Leinen to a motive to commit arson against Metzger, I believe the district court did not properly balance the prejudice against the probative value. Committing domestic abuse is socially unacceptable and generally — and properly — condemned by much of modern society. The prejudice related to such evidence is great. One can clearly see the propensity argument: if Farish is bad enough to beat his girlfriend, he is bad enough to firebomb her friend’s house. In this case, the probative value is so extremely weak that I believe the prejudice clearly outweighs any value to the eviden-tiary record.

I do agree with the majority’s analysis, for the reasons stated in the majority opinion, that the evidence against Farish was strong and that the admission of the § 404(b) evidence was harmless error.

Accordingly, I concur in the opinion.