Dorman v. United States

491 A.2d 455, 1984 D.C. App. LEXIS 587
CourtDistrict of Columbia Court of Appeals
DecidedApril 25, 1985
Docket81-1302
StatusPublished
Cited by35 cases

This text of 491 A.2d 455 (Dorman v. United States) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dorman v. United States, 491 A.2d 455, 1984 D.C. App. LEXIS 587 (D.C. 1985).

Opinions

BELSON, Associate Judge.

The reconsideration of this appeal gives the en banc court an opportunity to consid[458]*458er this jurisdiction’s law on impeachment of defendants by previous convictions.

Appellant contends that the sequence of the prosecutor’s questions during appellant’s cross-examination suggested to the jury that because appellant had been convicted of past offenses he must be guilty of the charged offense. A majority of a division of this court affirmed appellant’s conviction of petit larceny, D.C.Code § 22-2202 (1981). Dorman v. United States, 460 A.2d 986 (D.C.1983). We vacated that opinion and granted rehearing en banc. We now affirm.1

I

D.C.Code § 14-305(b)(1) (1981) controls the admission into evidence of a defendant’s previous convictions. The section reads, in part:

[F]or the purpose of attacking the credibility of a witness, evidence that the witness has been convicted of a criminal offense shall be admitted if offered, either upon the cross-examination of the witness or by evidence aliunde, but only if the criminal offense (A) was punishable by death or imprisonment in excess of one year under the law under which he was convicted, or (B) involved dishonesty or false statement (regardless of punishment). A party establishing conviction by means of cross-examination shall not be bound by the witness’ answers as to matters relating to the conviction.

The jury can infer from a witness’ previous convictions that the witness may be untruthful in his present testimony. When the defendant is a witness in his own case, there is a danger that the jury will draw the impermissible inference from the defendant’s past convictions that he is guilty of the current offense. The danger is especially great if the past crimes are similar to the current offense. But this court is not free to decide that the danger of prejudice to the defendant warrants barring impeachment by previous convictions. Congress has prescribed that certain convictions are relevant to a factfinder’s credibility determinations. We are bound by Congress’ policy decision. Hill v. United States, 434 A.2d 422, 429 (D.C.1981), cert. denied, 454 U.S. 1151, 102 S.Ct. 1020, 71 L.Ed.2d 307 (1982).

It is within our province, however, to require procedures that minimize the risk that a jury will misuse the evidence of previous convictions which Congress has declared admissible. In that way we accommodate both Congressional policy and the interest of avoiding unnecessary prejudice to defendants. In past cases we have [459]*459recognized that the sequence of the prosecutor's questions on cross-examination can prompt the impermissible inference. For example, in Fields v. United States, 396 A.2d 522 (D.C.1978), appellant was charged with various armed offenses and with carrying a pistol without a license. The prosecutor opened his cross-examination of the appellant by asking:

Q. Now, Mr. Fields, you had a gun with, you that night; didn’t you?
A. No, sir.
Q. Are you the same Jesse Fields that was convicted in 1969 of carrying a pistol without a license?

Appellant replied that he was. Id. at 526. The prosecutor repeated the sequence, asking about appellant’s previous conviction for possession of an unregistered firearm. We held that the questions about appellant’s previous weapon convictions, asked “immediately after appellant had denied possessing a gun on the occasion of the offense charged, likely gave the jury the impression that evidence of appellant’s prior conviction was being offered to rebut appellant’s .denial.” Id. at 527. The questioning constituted reversible error.

In Bailey v. United States, 447 A.2d 779 (D.C.1982), a division of this court held that the following set of questions at the end of government cross-examination was plain error:

Q. You didn’t try to rape her down there, is that right?
A. That’s correct.
Q. Are you the same Phillip Bailey who on May 14, 1971, was convicted in the United States District Court for the District of Columbia of armed rape?
A. Yes, I am.

Id. at 781. We disagreed with the trial judge’s conclusion that the prosecutor’s pause before the question about the previous conviction provided a buffer sufficient to avoid a prejudicial juxtaposition of general denial and impeachment by conviction of a similar offense. Id. at 783.

In Baptist v. United States, 466 A.2d 452 (D.C.1983), we distilled some general rules from Fields, Bailey, and two nonbinding D.C. Circuit cases, United States v. Henry, 174 U.S.App.D.C. 88, 528 F.2d 661 (1976), and United States v. Carter, 157 U.S.App.D.C. 149, 482 F.2d 738 (1973). We now approve most of Baptist’s analysis. There are two general prohibitions. First, the government may not pair questions about a defendant’s previous convictions for offenses similar to those charged with questions that elicit his general denial of the charged crime. Bailey exemplifies this prohibition. Second, the government may not pair questions about similar previous convictions with questions that elicit defendant’s denial of a key element of the charged offense. Fields exemplifies this rule. The second proscription will be the more difficult to apply, because many cross-examination questions necessarily refer to elements of the charged crime, and a defendant’s answer may imply a denial of the element.2

[460]*460We observe that in some instances impeachment by previous convictions not similar to the charged crime may be so obviously misused as to become objectionable. On the other hand, impeachment by previous convictions juxtaposed with examination on matters related solely to credibility will ordinarily be unobjectionable.3 Obviously we cannot set out in advance specific rules governing the innumerable varieties of examination that may take place in particular cases.4 We can articulate only a general standard by which particular instances of impeachment can be judged. The test is whether the prosecutor’s reference to a defendant’s previous conviction is such that, under the circumstances, reasonable jurors would naturally and necessarily regard the manner in which the impeachment is accomplished as implying that the defendant is guilty of the crime charged because he was guilty of past crimes.5 Our test focuses on the manner of impeachment because we acknowledge that to some degree the mere fact of previous conviction impeachment imparts “well-nigh inescapable prejudice .on the issue of guilt.” Carter, 157 U.S.App.D.C. at 151, 482 F.2d at 740.

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Bluebook (online)
491 A.2d 455, 1984 D.C. App. LEXIS 587, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dorman-v-united-states-dc-1985.