United States v. Abel case brief summary
469 U.S. 45 (1984)
CASE FACTS
Defendant and two others were charged with bank robbery. The two co-defendants pleaded guilty, and one agreed to testify against defendant. Defendant countered with a witness to impeach the testimony of the co-defendant. The co-defendant was then permitted to testify regarding the witness's membership in a prison gang that would commit perjury on its members' behalf.
PROCEDURAL HISTORY
The trial court admitted the evidence, and defendant was convicted. Defendant sought review and argued that the rebuttal testimony lacked probative value and did not outweigh the prejudicial effect. The appellate court reversed his conviction and found that the testimony prejudiced defendant because it implicated him as gang member and had the effect of impeachment, even though he did not take the stand. The United States sought review.
DISCUSSION
The court reversed the decision of the appellate court, which reversed defendant's conviction, reinstated the trial court's judgment, and affirmed the defendant's conviction for bank robbery because the trial court did not err when it admitted impeachment testimony.
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469 U.S. 45 (1984)
CASE SYNOPSIS
Petitioner United States sought review
of a decision by the Court of Appeals for the Ninth Circuit, which
reversed the defendant's conviction for bank robbery.CASE FACTS
Defendant and two others were charged with bank robbery. The two co-defendants pleaded guilty, and one agreed to testify against defendant. Defendant countered with a witness to impeach the testimony of the co-defendant. The co-defendant was then permitted to testify regarding the witness's membership in a prison gang that would commit perjury on its members' behalf.
PROCEDURAL HISTORY
The trial court admitted the evidence, and defendant was convicted. Defendant sought review and argued that the rebuttal testimony lacked probative value and did not outweigh the prejudicial effect. The appellate court reversed his conviction and found that the testimony prejudiced defendant because it implicated him as gang member and had the effect of impeachment, even though he did not take the stand. The United States sought review.
DISCUSSION
- The court reversed the appellate court and reinstated the conviction.
- The court found that it was permissible under the Federal Rules of Evidence to impeach a witness by showing his bias and that the rebuttal testimony was sufficiently probative of the possible bias to warrant admission.
The court reversed the decision of the appellate court, which reversed defendant's conviction, reinstated the trial court's judgment, and affirmed the defendant's conviction for bank robbery because the trial court did not err when it admitted impeachment testimony.
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