Brief Fact Summary. Ernestine James’s (Defendant-Appellant’s) boyfriend, David Ogden (decedent) was killed by Defendant-Appellant’s daughter, Jaylene Jeffries (Jeffries), and, as a result, Defendant-Appellant was convicted by a Federal District Court of the crime of aiding and abetting manslaughter. At trial, Defendant-Appellant raised the defense of self-defense in the original action. A dividend panel of the 9th Circuit Court of Appeals affirmed her conviction in her first appeal, and she appeals that decision here. The 9th Circuit Court of Appeals reverses the conviction.
Synopsis of Rule of Law. Where a Defendant raises self-defense as a defense to a charge of manslaughter, it is improper under the Federal Rules of Evidence to exclude extrinsic evidence of the decedent’s violent nature that would have corroborated the Defendant’s testimony.
Because the crux of the defendant's defense rested on her credibility and because her credibility could be directly corroborated through the excluded documentary evidence, exclusion of the documents was prejudicial and more probably than not affected the verdict.View Full Point of Law
Is corroboration of a prosecution witness by admission of criminal records permissible, even when such an admission may prejudice a defendant on trial?
Did the District Court abuse its discretion under Federal Rule of Evidence 403 by not admitting the corroborating evidence based on the danger of unfairly prejudicing the jury against the decedent?
Held. The 9th Circuit Court of Appeals reverses the conviction, and holds as follows:
Yes; corroboration of a prosecution witness by the admission of criminal records is permissible, so long as the probative value of the evidence is not outweighed by the danger of unfair prejudice.
Yes; the District Court did abuse its discretion by not admitting the evidence based on the danger of unfairly prejudicing the jury against the decedent, as the proper standard was the danger of unfair prejudice as to the Defendant-Appellant’s credibility, not as to the character of the decedent.
Dissent. The dissenting opinion is based on the discretion afforded the trial judge; the dissent argues that the instant court must “defer to the trial judge’s discretion, when the trial judge had a sensible reason for exercising his discretion as he did.”
The majority holds that because the, “crux of [Defendant-Appellant’s] defense rested on her credibility and because her credibility could be directly corroborated through the excluded documentary evidence, exclusion of the documents was prejudicial” to Defendant-Appellant. The majority’s decision to reverse, therefore, was based on what it perceived as an error by the lower court in considering the prejudicial value of the evidence as it relates to the decedent, not to Defendant-Appellant. Evidence of the decedent’s violent past behavior would have corroborated Defendant-Appellant’s testimony, and should have been admitted.
The dissent does not hold that the trial judge should have admitted or not admitted the evidence; rather, the dissent points out that the trial judge’s decision to not admit the evidence was based on “good reasons,” and therefore, that decision should be upheld.