Brief Fact Summary. Defendant, Michael Lipscomb, was convicted of heroin possession and intent to distribute in a second trial. The prosecution used prior convictions to impeach him and three defense witnesses. The district court did not extensively look into the facts and circumstances surrounding the prior convictions of the three defense witnesses.
Synopsis of Rule of Law. Evidence of prior felony convictions may be admitted only if the court determines that the probative value outweighs the prejudicial effect to the defendant.
Judge Learned Hand has described it as the recommendation to the jury of a mental gymnastic which is beyond, not only their powers, but anybody's else.View Full Point of Law
Issue. To what extent must a district court seek additional information regarding the facts and circumstances surrounding prior convictions used to impeach?
Held. Justice Wald issued the opinion for the United States Court of Appeals for the District of Columbia in holding that it is in the district court’s discretion in determining when to inquire into the facts and circumstances and to what extent regarding a prior conviction.
Discussion. The Court of Appeals finds that looking into facts and circumstances surrounding prior convictions can only help a court weigh the probative value versus prejudicial effect. The Court of Appeals declines to say exactly to what extent a court should inquire and granting courts substantial discretion.