Alford v. United States
282 U.S. 687 (1931)
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Rule of Law:
In a federal criminal trial, it is a prejudicial abuse of discretion for the court to prevent defense counsel from asking a prosecution witness on cross-examination where they live, as this is an essential line of inquiry for identifying the witness, testing their credibility, and uncovering potential bias.
Facts:
- The petitioner, Alford, was charged with using the mails to defraud.
- A former employee of Alford served as a key witness for the prosecution.
- The witness gave damaging testimony regarding uncorroborated conversations he allegedly had with Alford when others were not present.
- The witness also testified about statements Alford supposedly made to salesmen whom the witness did not identify.
Procedural Posture:
- The petitioner was prosecuted for mail fraud in the U.S. District Court for the Southern District of California.
- During trial, on cross-examination of a key prosecution witness, defense counsel asked the witness for his address.
- The trial court sustained the government's objection that the question was immaterial and not proper cross-examination.
- Defense counsel later argued, outside the jury's presence, that he had reason to believe the witness was in federal custody, a fact relevant to showing bias, but the court adhered to its ruling.
- The petitioner was convicted.
- The petitioner appealed to the U.S. Court of Appeals for the Ninth Circuit, which affirmed the conviction.
- The U.S. Supreme Court granted certiorari to review the appellate court's judgment.
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Issue:
Does a trial court commit prejudicial error by refusing to allow a defendant's counsel on cross-examination to ask a key prosecution witness for his place of residence, thereby preventing an inquiry into the witness's background and potential bias?
Opinions:
Majority - Mr. Justice Stone
Yes. A trial court commits prejudicial error by cutting off all inquiry into a witness's residence because cross-examination is a matter of right essential for a fair trial. The purposes of cross-examination include identifying a witness with their community, allowing the jury to interpret testimony based on the witness's environment, and eliciting facts that could show bias or discredit the testimony. Asking "Where do you live?" is a fundamental and appropriate preliminary question to place the witness in his proper setting. To deny the defense this opportunity, especially when counsel suspects the witness is in federal custody and may be testifying under duress or in exchange for leniency, withdraws a safeguard essential to a fair trial. While a trial court has discretion to control the extent of cross-examination, it is an abuse of that discretion to cut off in limine (at the beginning) an entire, proper subject of inquiry.
Analysis:
This case solidifies the principle that cross-examination as to a witness's background is not a mere privilege but a fundamental right of the accused. By holding that prejudice ensues from the denial of this right, the Court established that a defendant need not prove what a proper cross-examination would have revealed. This decision places a significant limit on a trial judge's discretion, distinguishing between the permissible power to curb repetitive or harassing questions and the impermissible act of foreclosing a foundational line of inquiry essential for testing credibility and bias, a right later understood as central to the Sixth Amendment's Confrontation Clause.
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