Summary
The United States Court of Appeals for the Eighth Circuit affirmed Robert Wilburn’s conviction for unlawful possession of a firearm and ammunition as a felon under 18 U.S.C. § 922(g)(1). The court held that the district court did not abuse its discretion by admitting evidence of Wilburn’s prior firearm-possession conviction and his parole release date under the rules governing relevance, prior acts, and unfair prejudice. The court also concluded that the evidence was sufficient to support the jury’s finding that Wilburn knowingly possessed the firearm and ammunition.
Court
United States Court of Appeals for the Eighth Circuit
Jurisdiction
United States Court of Appeals for the Eighth Circuit
Decision date
April 3, 2026
Docket number
25-1234
Disposition
affirmed
Questions Presented
- Whether the district court abused its discretion by admitting Wilburn's prior conviction for unlawful possession of a firearm by a felon under Federal Rule of Evidence 404(b) to prove knowledge and intent.
- Whether the district court abused its discretion by admitting evidence that Wilburn was released on parole the day before the firearm was purchased.
- Whether sufficient evidence supported Wilburn's conviction for knowingly possessing the firearm and ammunition as a felon.
Holdings
- The district court did not abuse its discretion by admitting evidence of Wilburn's prior conviction for unlawful possession of a firearm by a felon to prove his knowledge and intent to possess the firearm and ammunition.
- The district court did not abuse its discretion by admitting testimony that Wilburn was released on parole the day before Swift purchased the firearm.
- The evidence was sufficient to support Wilburn's conviction for knowingly possessing the firearm and ammunition as a felon.
Court Document
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