People v. Armstrong, 36 A.D.2d 100 (N.Y. App. Div. 1971)
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A defendant is entitled to broad cross-examination of a key witness regarding the circumstances of the witness’s own criminal plea and discharge, especially when it may reveal potential bias or motivation for testifying.
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Summary
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Armstrong was convicted of selling LSD. The key witness, Petrie, testified she saw Armstrong give LSD to another person. Petrie herself had been charged with selling LSD and received an unconditional discharge. The defense attempted to question Petrie about whether her discharge was contingent upon her testimony, but the trial court intervened, limiting the inquiry. The appellate court reversed, holding that the defendant was improperly restricted from exploring potential bias or motivation in Petrie’s testimony related to her own criminal case resolution. This case highlights the importance of allowing broad cross-examination to assess witness credibility, particularly when the witness’s testimony is crucial to the prosecution’s case.
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Facts
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Armstrong was convicted of selling LSD based on an incident on February 28. Police seized 182 LSD tablets in a raid on a farmhouse on March 23, but Armstrong wasn’t present during the raid. The prosecution’s case rested heavily on the testimony of Betty Petrie, an occupant of the farmhouse. Petrie testified that she saw Armstrong give another occupant, Muhl, a substance wrapped in tinfoil, resembling LSD, on February 28.
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Procedural History
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Armstrong was convicted of selling LSD in the trial court. He appealed the conviction, arguing that the trial court improperly limited his ability to cross-examine a key witness. The appellate division reversed the conviction and ordered a new trial.
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Issue(s)
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Whether the trial court improperly limited the defendant’s right to cross-examine a key prosecution witness regarding the circumstances of the witness’s own criminal charge and subsequent unconditional discharge, thereby potentially concealing bias or motivation for testifying.
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Holding
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Yes, because the defendant was entitled to broad inquiry into the circumstances of the witness’s plea and unconditional discharge to determine whether any condition had been attached to it related to her testimony.
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Court’s Reasoning
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The appellate court reasoned that Petrie’s credibility was a critical issue in the case, as her testimony was essential for Armstrong’s conviction. Petrie had been charged with selling LSD and received an unconditional discharge. The defense was entitled to explore the circumstances of that discharge to uncover any potential bias or motivation she might have had for testifying for the prosecution. The court noted that Petrie’s initial statements to the police and her first grand jury testimony did not implicate Armstrong. It was only after she pleaded in her own case that she implicated him, and she subsequently received the unconditional discharge. The trial court’s intervention, preventing full inquiry into these circumstances, was deemed prejudicial. The court cited People v. Savvides, 1 N.Y.2d 554, and People v. Mangi, 10 N.Y.2d 86, emphasizing the importance of allowing broad cross-examination to assess witness credibility, especially when a witness may have a motive to fabricate or shade their testimony. The court stated that the intervention of the judge also