Stanton Guillory v. United States

Federal Rule of Evidence 404(b) prohibits the use of a defendant’s other bad acts to argue he has a propensity to commit a crime. The Government nevertheless used Stanton Guillory’s alleged involvement in three other murders to argue he had a “mentality” that made him “willing to kill” a witness in a healthcare fraud case. The district court admitted evidence of the other murders on the premise that it fell outside Rule 404(b). It reasoned the other murders “completed the story” and so applied the so-called “inextricably intertwined” exception. Circuits are split on whether the exception exists. The question presented is: Is there an “inextricably intertwined” exception to Rule 404(b)?