Tenth Circuit: United States v. Willis

FRE, Due Process, Miranda

No error in introduction of prior bad acts where the conduct was similar and spoke to the specific question in the present case.

Where tribal law required juvenile records to be expunged, and, contrary to that law, the records are later transmitted to another jurisdiction for use in a criminal case, there is no Due Process violation in the second forum.

Where deft invokes right to counsel, subsequent administrative questioning for 30 minutes does not preclude a subsequent immediate waiver of the right.

As deft could attack credibility of victim under the same theory in other ways, no error in exclusion of victim's history.

Where objection for vouching is unspecific, and deft elicits avouching of vouching on cross, review is for plain error.

Where only one harmless error is found on review, no cumulative error.

United States v. Willis