Charles Alan Wright & Kenneth W. Graham, Jr., 22A Federal Practice and Procedure: Evidence § 5242 (2d ed. 2013) (“[T]he routine use of [the intent] exception [under Rule 404(b) ] could easily destroy the exclusionary rule.”). We join other circuits in declaring that a possession conviction is inadmissible to prove intent to distribute. The Sixth Circuit, for example, held that “possession of a small quantity of crack cocaine for personal use on one occasion ... sheds no light on whether [the defendant] intended to distribute crack cocaine in his possession on another occasion nearly five months earlier.” United States v. Haywood, 280 F.3d 715, 721 (6th Cir.2002). The Seventh and Ninth Circuits have suggested likewise. See United States v. Santini, 656 F.3d 1075, 1078 (9th Cir.2011) (<HOLDING>); Ono, 918 F.2d at 1465 (distinguishing between
holding that prior convictions for possession of cocaine and marijuana are admissible to impeach defendant holding that convictions for trafficking possession and simple possession ofcocaine offended double jeopardy protections holding that the probative value of prior felony convictions varies with their nature and number holding that possession of more than seven tons of marijuana justified the district courts refusal to provide a simple possession instruction holding that prior convictions for simple possession were not similar to the importation of marijuana and thus lack probative value