Green v. Bock Laundry Mach. Co.

490 U.S. 504 (1989)

 

RULE:

Fed. R. Evid. 609(a)(1) requires a judge to permit impeachment of a civil witness with evidence of prior felony convictions regardless of ensuing unfair prejudice to the witness or the party offering the testimony.

FACTS:

In a products liability action, petitioner injured party sought review of a judgment of the Court of Appeals, which affirmed a trial court judgment in favor of respondent manufacturer. The trial court's judgment followed the manufacturer's use of evidence of the injured party's felony convictions for impeachment purposes. The injured party was a prison inmate who was on a work release program when he was injured by the manufacturer's product. For purposes of impeachment at trial, the manufacturer produced evidence of the injured party's two prior felony convictions. The injured party contended that the trial court erred by denying his pretrial motion to exclude the impeaching evidence. 

ISSUE:

Whether Fed. R. Evid. 609(a)(1) required a judge to permit impeachment of civil witnesses with evidence of prior felony convictions regardless of ensuing unfair prejudice to the witness or the party offering the testimony?

 

ANSWER:

Yes.

CONCLUSION:

The Court held that Fed. R. Evid. 609(a)(1) required a trial judge to permit impeachment of civil witnesses with evidence of prior felony convictions regardless of ensuing unfair prejudice to the witness or the party offering the testimony. The Court found that Rule 609(a)(1)'s exclusion of civil witnesses from its weighing language was a specific command that impeachment of witnesses like the injured party be admitted. Further, the command of Rule 609(a)(1) overrode a judge's general discretionary authority under Fed. R. Evid. 403 to balance probative value over prejudice to civil witnesses. For that reason, there was no error when the jury learned through impeaching cross-examination that the injured party was a convicted felon. The Court affirmed the judgment in favor of the manufacturer and the denial of the injured party's motion to exclude impeaching evidence.

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