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Hines v. The State

Supreme Court of Georgia
249 Ga. 257, 290 S.E.2d 911 (1982)
ELI5:

Rule of Law:

The Sixth Amendment's Confrontation Clause guarantees a criminal defendant the right to cross-examine a key state's witness about that witness's pending criminal charges to expose potential bias, prejudice, or ulterior motives. A trial court's complete prohibition of this line of inquiry constitutes a prejudicial abuse of discretion.


Facts:

  • An armed robbery occurred at a package store.
  • The robber wore a mask, preventing the store's cashier from making an identification.
  • Steve Henderson was with the appellant on the night of the robbery.
  • Henderson was the only witness to identify the appellant as the perpetrator, testifying that the appellant left the car for a few minutes and returned stating he had just robbed the store.
  • At the time of his testimony, Henderson was being held in jail in an adjoining county due to his arrest on separate, pending burglary charges.

Procedural Posture:

  • The appellant was charged with armed robbery in a Georgia trial court.
  • Prior to trial, the defense filed a Brady motion seeking the criminal records of state witnesses, which the trial judge denied.
  • At the commencement of trial, the prosecution made an oral motion in limine to prevent the defense from cross-examining witness Steve Henderson about his pending burglary charges.
  • The trial judge granted the prosecution's motion in limine.
  • Following a trial, the appellant was convicted of armed robbery.
  • The appellant appealed his conviction to the Georgia Court of Appeals, which affirmed the trial court's judgment.
  • The appellant's application for a writ of certiorari was granted by the Supreme Court of Georgia.

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Issue:

Does a trial court's order, granting a motion in limine to prevent a criminal defendant from cross-examining the state's sole identification witness about that witness's pending criminal charges, violate the defendant's Sixth Amendment right to confrontation?


Opinions:

Majority - Marshall, Justice.

Yes. A trial court's order preventing a criminal defendant from cross-examining the state's sole identification witness about pending criminal charges violates the defendant's Sixth Amendment right to confrontation. The Confrontation Clause guarantees the right to cross-examine a key witness concerning pending charges to reveal possible biases, prejudices, or ulterior motives. Citing Davis v. Alaska, the court reasoned that exposing a witness's motivation for testifying is a critical function of this constitutional right. The court emphasized that the existence of an explicit deal is not crucial; what matters is whether the witness might be shading their testimony in an effort to please the prosecution, even subconsciously. Because the trial court cut off all inquiry on this subject, it abused its discretion and committed prejudicial error. The court separately held that Brady v. Maryland does not obligate the prosecution to seek out information, such as a witness's criminal record, that is not already in its possession.



Analysis:

This decision reaffirms and strengthens a defendant's Sixth Amendment right to impeach a key government witness for bias. It clarifies that the right to cross-examine on pending charges is not contingent on proving an explicit deal for leniency; the mere potential for the witness to curry favor with the state is sufficient to make the inquiry constitutionally necessary. The case draws a sharp line between the prosecution's disclosure duties under Brady (which do not include investigating for the defense) and the defendant's separate constitutional right to probe for bias through cross-examination at trial. This precedent solidifies the defense's ability to challenge the credibility of witnesses who have a personal stake in cooperating with the government, ensuring juries are aware of potential ulterior motives.

G

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