Green v. Bock Laundry Machine Co.
490 U.S. 504 (1989)
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Rule of Law:
Federal Rule of Evidence 609(a)(1) requires a judge to admit evidence of a witness's prior felony convictions for impeachment purposes in a civil case, as the rule's balancing test for weighing probative value against prejudicial effect applies exclusively to criminal defendants.
Facts:
- Paul Green was an inmate at a county prison participating in a work-release program.
- Green was employed at a car wash.
- On his sixth day of work, Green's right arm was torn off when he reached inside a large clothes dryer to stop it.
- The dryer was manufactured by Bock Laundry Machine Co.
- At the time of the incident, Green had prior felony convictions for conspiracy to commit burglary and burglary.
Procedural Posture:
- Paul Green filed a product liability suit against Bock Laundry Co. in federal district court.
- Prior to trial, Green filed a motion to exclude evidence of his prior felony convictions, which the district court denied.
- At trial, Bock impeached Green's testimony with his prior felony convictions for burglary and conspiracy.
- The jury returned a verdict for the defendant, Bock Laundry Co.
- Green appealed to the U.S. Court of Appeals for the Third Circuit, which summarily affirmed the district court's ruling.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the circuits.
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Issue:
Does Federal Rule of Evidence 609(a)(1) require a trial court in a civil case to permit the impeachment of a witness with evidence of prior felony convictions?
Opinions:
Majority - Justice Stevens
Yes. Federal Rule of Evidence 609(a)(1) requires a trial court in a civil case to admit prior felony conviction evidence for impeachment purposes. The Court reasoned that a literal reading of the rule's text, which allows for balancing the prejudicial effect 'to the defendant,' leads to an absurd result in civil cases by protecting civil defendants but not civil plaintiffs. Examining the legislative history, the Court determined Congress deliberately limited this balancing test to criminal defendants to protect them from the unique prejudice of a jury inferring guilt from a prior record. For all other witnesses, including all parties in a civil case, Congress rejected a balancing test, meaning the rule's command that such evidence 'shall be admitted' is mandatory and overrides the general discretion granted to judges under Rule 403.
Concurring - Justice Scalia
Yes. The judgment that the evidence must be admitted is correct. A literal interpretation of 'defendant' in Rule 609(a)(1) would produce an absurd and potentially unconstitutional result by protecting civil defendants but not civil plaintiffs. The most sensible interpretation, which does the 'least violence to the text,' is that 'defendant' refers only to a 'criminal defendant.' This interpretation is consistent with the law's general policy of providing special protections in criminal cases. Therefore, the balancing test does not apply in civil proceedings, and the specific mandate of Rule 609(a)(1) forecloses the application of Rule 403's general balancing test.
Dissenting - Justice Blackmun
No. The Rule should be interpreted to allow judicial balancing for all parties, not to mandate admission of prejudicial evidence in civil cases. The majority's reading endorses an irrational and unfair result based on inartful legislative drafting. A better interpretation would be to read 'prejudice to the defendant' as 'prejudice to a party,' which would be consistent with the Conference Committee's underlying concern about evidence that could 'improperly influenc[e] the outcome of the trial.' The majority's interpretation creates a 'trap for the unwary' attorney who relies on the rule's plain text and denies trial courts the ability to ensure fairness in civil litigation as envisioned by Rule 102.
Analysis:
This decision established a rigid, bright-line rule requiring the admission of prior felony convictions against any witness in a civil case, removing judicial discretion under Rule 403. By interpreting 'defendant' in Rule 609(a)(1) to mean only 'criminal defendant,' the Court elevated a strict reading of legislative history over broader principles of fairness in civil litigation. The ruling was highly controversial for its potential to unfairly prejudice civil litigants, prompting Congress to amend Rule 609(a) in 1990. The amendment effectively overturned this decision by explicitly extending a balancing test to all witnesses in civil cases, making the case a prominent example of statutory interpretation leading to legislative reversal.
