People v. Mayrant, 43 N.Y.2d 236 (1977)
A defendant who testifies may be cross-examined about prior immoral, vicious, or criminal conduct only if it bears on their credibility as a witness, not merely to show a propensity to commit the crime charged; the trial court must balance the probative value of such evidence against the risk of unfair prejudice.
Summary
Harold Mayrant was convicted of second-degree assault for stabbing a friend. Prior to trial, Mayrant sought a ruling to prevent the prosecution from using his prior convictions to impeach his credibility if he testified. The trial court denied the motion, reasoning that the convictions demonstrated Mayrant’s propensity for violence, which was relevant to determining who was the aggressor. The Appellate Division affirmed. The Court of Appeals reversed, holding that the trial court failed to properly balance the probative value of the prior convictions against the risk of unfair prejudice to the defendant, warranting a new trial.
Facts
Harold Mayrant was charged with assault in the second degree for stabbing Alexander Woods, who was described as a friend. Before trial, Mayrant sought a ruling to prevent the prosecution from using two prior convictions to impeach him if he testified. One conviction stemmed from an incident where Mayrant fired shots at a robber and pleaded guilty to weapon possession. The second arose from an altercation where Mayrant struck a man with a golf club, pleading guilty to harassment. The trial court ruled the convictions were admissible to show Mayrant’s propensity for violence.
Procedural History
Mayrant was convicted of assault in the second degree. He appealed to the Appellate Division, which affirmed the conviction. He then appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in denying the defendant’s Sandoval motion by failing to properly balance the probative value of the defendant’s prior convictions against the risk of unfair prejudice when assessing their admissibility for impeachment purposes.
Holding
Yes, because the trial court’s ruling suggested it only considered the defendant’s propensity for violence, failing to balance that against the potential for unfair prejudice, thus warranting a new trial.
Court’s Reasoning
The Court of Appeals emphasized that while a defendant can be cross-examined about prior immoral, vicious, or criminal conduct, it must bear on their credibility as a witness, not simply demonstrate a propensity to commit the crime charged. The Court cited People v. Sandoval, noting that a balance must be struck between the probative worth of evidence of prior misconduct on the issue of credibility and the risk of unfair prejudice to the defendant. The Court found that the trial judge’s reasoning, focusing solely on Mayrant’s “prior propensities for committing violent acts,” indicated a failure to consider this balance. The Court stated, “That an altercation took place is not disputed…The only serious issue was justification…it is impossible to say whether the Trial Judge, had he weighed all the considerations we have articulated, would not have limited the cross-examination as to prior criminal acts and whether, if he had done so, the scales would have been tipped for instead of against the defendant.” The Court further explained that allowing cross-examination solely to show propensity violates the principle that “[o]ne may not be convicted of one crime * * * because he committed another” (citing People v. Goldstein, 295 NY 61, 64). Because the only serious issue was justification and Mayrant was his own eyewitness, the court held the error was not harmless and a new trial was required.