If a pattern of behavior of a natural person does not rise to the status of a habit, it may constitute a character trait and such non-habitual behavior may be barred by the prohibition against circumstantial character evidence.

Fed. R. Evid. 609(a)(1) ("(a) General rule. For the purpose of attacking the character for truthfulness of a witness, (1) evidence that a witness other than an accused has been....If a conviction is offered to impeach a witness and the conviction is not for a crime that involves dishonesty or false statement, the conviction of the witness may be used to impeach the witness if the crime for which the witness was convicted is punishable by death or imprisonment for more than a year, if the crime the witness committed is probative of the truthfulness of the witness, and if the opponent fails to show that the risk of prejudice or other harm mentioned in Federal Rule of Evidence 403 outweighs the probative value of the conviction; but if the witness to be impeached is a criminal defendant, the prosecution bears the burden of showing that the probative value of the conviction outweighs the risk of prejudice to the defendant.

United States v. Mitchell, 328 F.3d 77, 82-83 (2d Cir. 2003) (upholding trial court's admission into evidence of accused's prior firearm arrest where to rebut accused's claim of ignorance, such evidence "was therefore relevant to whether [accused] knew that his conduct was illegal and,...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.

United States v. Davis, 181 F.3d 147, 149 (D.C. Cir. 1999) (upholding trial court's admission of officer's redacted buy report as pretrial identification because in a case with similar facts, the court "affirmed the....A pretrial identification is exempt from the prohibition against hearsay evidence if the witness who made the identification testifies and is subject to cross-examination at the trial or hearing at which the identification is offered and if the witness who made the identification did so after perceiving the person whom he or she identified.