People v. Melendez, 526 N.E.2d 640 (N.Y. 1988)
A party cannot introduce prior consistent statements to bolster their credibility on unrelated matters simply because the opposing party used a portion of the same statement to impeach the party on a specific issue.
Summary
Melendez was convicted of murder, attempted murder, and weapon possession. At trial, he claimed justification, arguing he acted in defense of another person being attacked by two brothers. The prosecution impeached Melendez’s testimony by introducing a portion of his post-arrest statement where he said the brothers attacked the victim with bare hands, not a stick. Melendez then sought to introduce the entire statement, arguing it would show he told police the brothers were armed when they approached him. The trial court refused, and the Court of Appeals affirmed, holding that introducing a prior consistent statement on an unrelated matter to bolster credibility is not permissible simply because a portion of the statement was used for impeachment on a specific issue. Relevance alone is not a sufficient basis for admitting a prior consistent statement.
Facts
During an incident, two men were shot, one fatally, leading to Melendez’s indictment on murder, attempted murder, and weapon possession charges.
At trial, Melendez asserted a justification defense, claiming he intervened in an altercation where two brothers were attacking another man with a stick.
He testified that the brothers then turned on him, one with a bat and the other with a cleaver.
On cross-examination, the prosecution introduced part of Melendez’s post-arrest statement, where he stated the brothers were using their bare hands, not a stick, to attack the initial victim.
Procedural History
Melendez was convicted at trial.
He appealed, arguing that the trial court erred by refusing to admit his entire post-arrest statement after the prosecution used a portion of it for impeachment.
The Appellate Division affirmed the conviction.
The New York Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether the trial court committed reversible error by refusing to admit Melendez’s entire post-arrest statement on redirect examination after the prosecution used a portion of it to impeach his testimony, when the remaining portions addressed an unrelated issue.
Holding
No, because the mere fact that a portion of a statement is raised by the prosecutor to impeach the defendant on a particular issue does not entitle the defendant to bolster his own credibility by introducing other portions containing prior consistent statements on unrelated matters.
Court’s Reasoning
The Court of Appeals reasoned that the issue of whether the brothers used a stick or their bare hands to attack the other person was distinct from whether the brothers were armed when they approached Melendez.
The portion of the post-arrest statement used by the prosecution was admissible as a prior inconsistent statement only to impeach Melendez’s trial testimony about the attack on the third person.
The court stated that while other relevant portions of the statement might have been admissible on the issue of whether the two men were armed when they approached Melendez, a proper foundation was not laid for that purpose.
The court emphasized that Melendez argued only that the statement was “relevant,” which is an insufficient basis for admitting a prior consistent statement.
The court noted that “the mere fact that a portion of a statement is raised by the prosecutor to impeach defendant on a particular issue does not entitle defendant to bolster his own credibility by introducing other portions containing prior consistent statements on unrelated matters.”
Therefore, the trial court did not err in refusing to admit the entire statement.