United States v. Enjady

A jury convicted Serefino Castillo of four counts of sexual abuse in violation of 18 U.S.C. § 2242(1) and four counts of sexual abuse of a minor in violation of 18 U.S.C. § 2243(a). At trial, the district court admitted certain evidence against the defendant pursuant to Federal Rule of Evidence 414. The defendant now appeals the admission of that evidence, contending (1) that Rule 414 was not effective at the time of his trial, (2) that Rule 414 violated his constitutional rights to due process and equal protection under the Fifth Amendment, as well as the right to be free of cruel and unusual punishment under the Eighth Amendment, and (3) that the Rule 414 evidence should have been excluded because of its great prejudicial value. We hold that Rule 414 was effective at the time of Mr. Castillos trial and that it does not violate the Constitution. We remand this case to the district court, however, for an adequate explanation of its Rule 403 determination.