Corroboration of a key prosecution witness by the introduction of criminal records is permissible, even at the risk of some prejudice to the defendant on trial.
Appelant James challenged the judgment of the United States District Court for the Western District of Washington on the basis that her conviction for aiding and abetting manslaughter was prejudiced by the exclusion of extrinsic evidence regarding the victim's prior violent misconduct.
Did the trial court err in excluding relevant evidence corroborating James’ testimony?
The Court held that the trial court erred in excluding relevant evidence corroborating appellant's testimony. The Court found that the trial court's interpretation of the evidence was too narrow. Because it was necessary to James’ defense that the jury believe her, the evidence should have been admitted because it corroborated her testimony. Because the crux of appellant's defense rested on her credibility and because the excluded evidence directly corroborated her credibility, exclusion of the evidence was prejudicial and more probably than not affected the verdict.