In this episode we examine the admission of uncharged acts occurring months after the alleged offenses for the purpose of common plan or scheme under Military Rule of Evidence 404(b). We discuss application of the Reynolds test, the decision in Hyppolite on common plan or scheme, the Wet Bandits from the 1990 American Christmas comedy film Home Alone, prejudice in appellate review, and distinctions in legal precedent in a fractured opinion. We also say thank you and farewell to Major Dustin Morgan on his last podcast.

Learn more about The Quill & Sword series of podcasts by visiting our podcast page at https://tjaglcs.army.mil/thequillandsword. The Quill & Sword show includes featured episodes from across the JAGC, plus all episodes from our four separate shows: “Criminal Law Department Presents” (Criminal Law Department), “NSL Unscripted” (National Security Law Department), “The FAR and Beyond” (Contract & Fiscal Law Department) and “Hold My Reg” (Administrative & Civil Law Department). Connect with The Judge Advocate General’s Legal Center and School by visiting our website at https://tjaglcs.army.mil/ or on Facebook (tjaglcs), Instagram (tjaglcs), or LinkedIn (school/tjaglcs).