Defendant's Letter Admitting Different Robbery Improperly Admitted, but Harmless.

U.S. v. Vaughan, 2011 WL 6160215 (12/13/11) (Kan.) (unpub'd) - The district court abused its discretion when it admitted the defendant's letter apologizing for robbing a bank other than the bank involved in the indictment. The admission violated Rule 403. The letter did not develop any modus operandi similarities to establish identity, but there was a possibility the jury could have interpreted it as a confession to the charged robbery. The error was nonetheless harmless due to overwhelming evidence.