Monday, April 29, 2013

United States v. James case brief

United States v. James case brief
169 F.3d 1210

CASE SYNOPSIS: Appellant challenged the judgment of the United States District Court for the Western District of Washington on the basis that her conviction for aiding and abetting manslaughter was prejudiced by the exclusion of extrinsic evidence regarding the victim's prior violent misconduct.

FACTS: Because the trial court erred in excluding relevant evidence corroborating appellant's testimony, the court reversed the judgment of appellant's conviction. Appellant was convicted of aiding and abetting manslaughter. At trial, appellant argued self-defense and attempted to introduce evidence corroborating appellant's knowledge of the victim's prior violent misconduct. Finding that the only relevant facts concerning the victim's past were the facts appellant knew about, the trial court ordered that the evidence be excluded from the jury's deliberations.

On appeal, the court found that the trial court's interpretation of the evidence was too narrow. Because it was necessary to appellant's defense that the jury believe her, the evidence should have been admitted because it corroborated her testimony. Because the crux of appellant's defense rested on her credibility and because the excluded evidence directly corroborated her credibility, exclusion of the evidence was prejudicial and more probably than not affected the verdict.

CONCLUSION: The court reversed the trial court's judgment, which convicted appellant of aiding and abetting manslaughter. The court concluded that extrinsic evidence regarding the prior violent misconduct of appellant's victim directly corroborated appellant's credibility, and therefore, the trial court's exclusion of the evidence was prejudicial.

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