Alaska v. McLaughlin
In Alaska v. McLaughlin, 860 P.2d 1270 (Alaska Ct. App. 1993), McLaughlin was charged with being a felon in possession of a concealable firearm. McLaughlin conceded the existence of a prior conviction, and the trial court ruled that evidence of McLaughlin's prior conviction would be withheld from the jury unless it became relevant to a specific disputed issue. See id. at 1272.
The Court of Appeals of Alaska, ruling on the State's petition to review the order, reversed. The court stated that resolution of the issue depended on whether it viewed it "as a narrow question of evidentiary relevance or a broader question involving policies that are not strictly evidentiary." Id. at 1273.
Adopting the latter view, the court concluded that the jury's "full understanding of the cause at issue -- the wrongdoing for which the accused has been held to answer" was "essential to its ability to fulfill its traditional role." Id. at 1277.
The court limited its holding, however, to cases "in which the charged offense consists of conduct that is ordinarily lawful, and is rendered unlawful only because of the defendant's prior conviction of a felony," as opposed to cases in which the prior conviction element "only enhances the seriousness of the offense." Id. at 1278 n.15.