Spangler v. United States

Background

A man was charged with several counts of extortion. At trial he testified and put on witnesses who described his good character and reputation. He asked the judge to tell the jury that good reputation evidence, by itself, could create reasonable doubt. The judge instead told jurors to weigh character evidence together with all other evidence. The jury convicted him and the Third Circuit affirmed that conviction.

Reasoning

The central issue described in the opinion is whether a judge must, or should, give a so-called "standing alone" instruction telling jurors that reputation evidence alone can create reasonable doubt. The opinion notes a clear split among the Courts of Appeals: some circuits say such an instruction is unnecessary or misleading, while others say it can be required in some cases. The opinion also points out that many pattern jury instructions include some version of the standing-alone language and that confusion traces back to earlier statements by this Court in Edgington and Michelson. The Supreme Court denied the petition asking for review of the Third Circuit’s decision.

Real world impact

Because the Court declined to hear the case, the Third Circuit’s ruling remains in place and no national clarification was issued. The disagreement among appeals courts about whether juries should be specially instructed about character evidence therefore continues. Trial judges, criminal defendants, and defense lawyers will still face differing rules depending on the circuit and on local pattern instructions.

Dissents or concurrances

Justice White dissented from the denial and said he would grant review to resolve the longstanding division among the appeals courts over the standing-alone instruction.