In Kirby v. United States (1899) 174 U.S. 47, the defendant was convicted of receiving stolen property. The convictions of the thieves in a separate trial were admitted at the defendant's trial to prove the property was stolen. The Supreme Court explained it was error "to admit in evidence the record of the conviction of the principal felons as competent proof for any purpose. That those persons had been convicted was a fact not necessary to be established in the case against the alleged receiver . . . ." (Id. at p. 60.) The Court also noted, "Where the statute makes the conviction of the principal thief a condition precedent to the trial and punishment of a receiver of the stolen property, the record of the trial of the former would be evidence in the prosecution against the receiver to show that the principal felon had been convicted . . . ." (Id. at p. 54.) Thus, the fact of another's conviction of a crime is admissible if relevant, but may not be used to prove that the underlying conduct involved in the crime occurred.