In this article, I argue that courts should not treat civil litigants in quasi-criminal cases the same as criminal defendants because character evidence can be used improperly as evidence of the propensity character. Part II of this article discusses the prohibition on admitting evidence of personality. Part III addresses the division among courts regarding whether this rule should apply in quasi-criminal cases. Part IV of this paper concludes that courts should resolve this division and refrain from treating civil parties in quasi-criminal cases as criminal defendants because the risk of prejudice does not support this use of the federal rules of evidence.II. The inadmissibility of character evidenceA. Before Federal RulesFederal Rule of Evidence 404 deals with the admissibility of character evidence. FRE 404(a)(1) lists the prohibited uses of character evidence and states that "Evidence of a person's character or character trait is inadmissible to demonstrate that on a particular occasion the person acted in accordance with the character or character trait". 1 This concept of “propensity character evidence” has been defined as the use of evidence in a trial about a person's character or character traits to demonstrate that that person has a tendency to act in a specific way.2 Therefore , if a person has a tendency to act in a certain way, it is more likely than not that the person acted in accordance with that tendency while committing a bad action. This concept now incorporated into the Federal Rules of Evidence can trace its philosophical underpinnings to pre-Revolutionary England. Before the 17th century, English courts had very few limitations on what evidence could be admitted in court.3 This court system, created following the Norman invasion in 1066, did not ... middle of paper .. ....470 F. 2d 432, 434-5 (DC Cir. 1972).Thomas J. Reed, Propensity Trial: Admission of Other Criminal Acts Evidenced in Federal Criminal Trials, 50 U. Cin. L. Rev. 713, 716 (1981). Glen Weissenberger, Making Sense of Extrinsic Act Evidence: Federal Rule of Evidence 404(b), 70 Iowa L. Rev. 579, 583 n. 17 (1985). Reed, supra note 28 , at 716-17. Weissenberger, supra note 29, at 579, 603 n. 75. Reed, supra note 28, at 717. People v. Shea, 41 NE 505, 511 (1895). Weissenberger, supra note 75, at 603. People v. Molineux, 61 NE 286, 302 (1901).Boyd v. United States, 142 US 450 (1892).Fed. R. Evid. 404(a) Advisory Committee Note.Fed. R. Evid.404.Christopher W. Behan, When the U-turn is Proper: Character Tests and Self-Defense in Murder and Assault Cases, 86 Or. L. Rev. 733, 746 (2007).Fed. R. Evid. 403.SEC v. Peters, 978 F.2d 1162, 1170 (10th Cir. 1992).