Citation. United States v. Lindstrom, 698 F.2d 1154, 1983)
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Brief Fact Summary.
Defendants, Joanne Lindstrom and Dennis Slater, were convicted of mail fraud and conspiracy to commit mail fraud after they manipulated billings and treatment for a therapy company that they owned.
Synopsis of Rule of Law.
A defendant has to prove that a delay in bringing an indictment was deliberate and prejudicial, but a court can not restrict a defendant’s right to cross-examine witnesses for the purposes of impeachment.
Defendants owned Bay Therapy, Inc. with a third person. Defendants hired a woman who became a key witness to the prosecution. The witness worked with government agents to gather evidence of Defendant’s wrongfully billing and treating patients of the company.
Two significant issues were presented in this case.
The first issue is whether the three-year delay between the beginning of the investigation and the indictment violated Defendants’ rights to due process and a speedy trial.
The second issue is whether the court’s restrictions on Defendants’ cross-examination violated their due process rights under the Sixth Amendment to the Constitution.
The Court offered holdings for each issue.
Defendants’ rights were not violated by the three-year delay. The Sixth Amendment to the United States Constitution does not apply to preindictment delay. And although there was evidence that the delay prejudiced Defendants’ case, they could not prove that the prosecution deliberately delayed the indictment to gain some type of advantage.
The Court held that the cross-examination restrictions did violate Defendants’ rights. Defendants had a right to delve into the mental state of the witness because their argument was that she was acting out of hatred to Defendants. The witness had a history of exceptionally abnormal behavior in acting out vendettas. The restriction against admitting psychiatric records and limiting cross-examination to prohibit questions of prior questionable conduct were unconstitutional limitations.
The end result is that the Court will always support evidence that is highly relevant to a defendant’s case. The State’s attempts to limit evidence in order to uphold an evidentiary rule will generally be overturned.