Seventh Circuit -- USA v. Fairly Earls

Limiting instruction was sufficient to allow evidence of potential state sentence for unrelated bad acts, as it was evidence of deft's motive to flee with fake passport data.

Police ID at trial of deft in photographs was harmless error.

For sentencing purposes, underlying conviction in the relevant section need not have already been obtained.  Language suggesting otherwise is surplussage because of  the cross-reference.

USA v. Fairly Earls