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Law School Case Brief

United States v. Manske - 186 F.3d 770 (7th Cir. 1999)


The U.S. Const. amend VI is not implicated every time a limit is placed on a defendant's right to expose bias. When a defendant is allowed to expose an individual's particular motive to lie, it is of peripheral concern to the U.S. Const. amend VI how much opportunity defense counsel gets to hammer that point down to the jury. If, however, the defense is completely forbidden from exposing the witness's bias or motive to testify, then the constitution is implicated. 


Thomas Manske was convicted by a jury of one count of conspiracy to distribute cocaine in violation of 21 U.S.C. § 846, and sentenced to 151 months in prison. His conviction was heavily based on the testimony of the government’s key witnesses. It appears, however, that the trial court allowed limitations on the cross-examination of the government’s key witnesses, particularly on the threats allegedly employed by one witness to the others. Manske appealed, seeking a new trial based on this alleged error.


Did the trial court err when it when it limited defendant's cross-examination of key witnesses?




The Court reversed the conviction and remanded. It found the trial court erred when it granted the motion in limine because the limitation impacted Manske's U.S. Const. amend. VI right to confront witnesses and because bias was one of the acceptable methods for attacking a witness' credibility.

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