Evidence – Other acts – harmless error

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U.S. Court of Appeals For the Seventh Circuit

Criminal

Evidence – Other acts – harmless error

Although it was error to admit other acts evidence without limiting its use to a permissible purpose, the error was harmless.

“Lawson’s best potential arguments are not presented for decision, and now we add that any error was harmless. The tax evidence could not have affected a rational jury’s verdict, given the undisputed proof that Lawson converted the fees to his personal use and did not spend the money for the purposes he told clients it was needed. His lawyer’s argument that hard times upset well-intentioned plans was embarrassed by the fact that Lawson lied when telling clients that he already had funding in hand. That he also lied about the firm’s past success in securing financing, and reneged on his promises to return fees if loans did not close, cemented the prosecution’s case.”

Affirmed.

14-1233 U.S. v. Lawson

Appeal from the United States District Court for the Northern District of Illinois, Zagel, J., Easterbrook, J.

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