Wednesday, December 18, 2013

Luce v. United States case brief

Luce v. United States case brief summary
469 U.S. 38 (1984)


CASE SYNOPSIS
Petitioner filed a petition for a writ of certiorari from the United States Court of Appeals for the Sixth Circuit concerning whether he was entitled to review of the district court's ruling denying his motion to forbid the use of a prior conviction to impeach his credibility where he had not testified at trial.

CASE FACTS
Petitioner filed a petition for a writ of certiorari from the appeals court concerning entitlement to review of the district court's ruling denying his motion to forbid the use of a prior conviction to impeach his credibility. Petitioner had not testified at trial and sought preclusion of a state conviction's use by the government if he had testified. The district court ruled that the prior conviction was permissible impeachment evidence under Fed. R. Evid. 609(a) if petitioner had testified and the scope of testimony was not limited. Petitioner appealed. The appeals court affirmed the district court judgment. The United States Supreme Court granted certiorari to resolve a conflict among the circuits as to whether a defendant, who did not testify at trial, was entitled to review where prior convictions were used to impeach credibility.

DISCUSSION

  • The Court affirmed the appeals court judgment and held that to raise and preserve for review the claim of improper impeachment with a prior conviction, a defendant had to testify. 
  • A court could not perform a balancing test between probative value and prejudicial effect otherwise.

CONCLUSION
The Court affirmed the judgment of the appeals court. The Court held that a defendant had to testify in order to raise and preserve for review the claim of improper impeachment with a prior conviction.

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