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Name: Charles v. Hickman
Court: US Court of Appeals
District 9 Cir
Opinion Date: 10/03/2000
Subsequent History: None

In a prior trial, Charles had been charged and acquitted of stabbing Bonton, a witness who had testified against him about a 1980 robbery. However, admission of that evidence did not violate the Fifth Amendment prohibition against double jeopardy. Charles was convicted of first-degree murder with special circumstances for shooting Darnell, also a witness against him in the earlier robbery trial. The prosecution introduced the evidence in question in order to prove Charles’ retaliatory motive and that the killing was intentional and premeditated. Evidence of the stabbing of Bonton was relevant to show that Charles shot Darnell, not in self-defense, but rather in retaliation for having snitched on him regarding the robbery. The evidence was therefore admissible to prove motive and intent, not to show disposition to commit the act. Because the issue of motive in the Bonton stabbing was governed by a lower standard of proof in the subsequent murder trial than in the original stabbing trial, the government was not precluded from relitigating the issue. Consequently, the evidence was not barred by the collateral estoppel component of the Double Jeopardy clause.