Hall v. State
2005 Wyo. LEXIS 40, 109 P.3d 499, 2005 WY 35 (2005)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under W.R.E. 608(b), extrinsic evidence of a witness's prior specific conduct, while generally inadmissible to attack their character for truthfulness, is admissible to prove the witness has a motive to testify falsely, such as bias or self-interest. The erroneous exclusion of such evidence may be deemed harmless if the jury possesses other sufficient information to make a discriminating appraisal of the witness's possible motives.
Facts:
- Brenda Schriner and Todd Harnden set up and operated a clandestine methamphetamine laboratory in Thomas S. Hall's home.
- The methamphetamine being refined in the laboratory allegedly belonged to Hall.
- Hall was present and knew what Schriner and Harnden were doing, but he did not actively participate in the laboratory's operation.
- In exchange for their testimony against Hall, Schriner and Harnden entered into favorable plea agreements with the State for their own criminal conduct.
- On a prior occasion, Schriner threatened to report Jim Mikolash to law enforcement if he did not perform favors for her, such as fixing her car.
- On another prior occasion, Schriner falsely accused John David Parker of possessing methamphetamine in order to divert the authorities' attention from herself.
Procedural Posture:
- The State charged Thomas S. Hall with conspiracy to engage in a clandestine laboratory operation in a Wyoming district court, the trial court of first instance.
- Before trial, Hall moved to admit testimony from two witnesses, Parker and Mikolash, concerning prior threats and false accusations made by the State's key witness, Brenda Schriner.
- The district court ruled the testimony inadmissible as extrinsic evidence of specific conduct under W.R.E. 608(b).
- Following a trial, a jury convicted Hall of the charge.
- Hall, as Appellant, appealed his conviction to the Supreme Court of Wyoming, the state's highest court, arguing the district court erred in excluding the witness testimony.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court violate a defendant's right to present a defense by excluding, under W.R.E. 608(b), extrinsic evidence of a key prosecution witness's prior specific acts of making false accusations, when that evidence is offered to show the witness's motive, bias, and self-interest in testifying for the state?
Opinions:
Majority - Hill, Chief Justice
Yes, the trial court erred by excluding the proffered testimony. W.R.E. 608(b)'s prohibition on extrinsic evidence of specific conduct applies only when attacking a witness's general character for truthfulness; it does not bar evidence offered to show bias, self-interest, or a specific motive to lie, which are not considered collateral issues. The testimony from Parker and Mikolash regarding Schriner's past threats and false accusations was relevant to show her bias and self-interest in testifying against Hall to secure a favorable plea deal. However, the court's error in excluding this evidence was harmless. The jury was already in possession of sufficient information to make a 'discriminating appraisal' of Schriner's credibility, including her plea deal, her reputation for dishonesty testified to by other witnesses, and the defense's vigorous arguments about her motive to lie. Therefore, the error does not mandate a reversal of the conviction.
Analysis:
This decision clarifies the scope of Rule of Evidence 608(b), establishing a clear distinction between using specific acts to prove a general character for untruthfulness (impermissible) and using them to prove a specific motive to lie, such as bias or self-interest (permissible). It reinforces that impeaching for bias is a distinct and favored method of attack that is not barred by the general prohibition on extrinsic evidence of misconduct. However, by finding the error harmless, the ruling signals that appellate courts will examine the totality of the evidence presented to the jury about a witness's credibility before reversing a conviction based on the wrongful exclusion of bias evidence, creating a high bar for appellants.
