Hileman v. Indreica

187 N.W.2d 411, 385 Mich. 1, 1971 Mich. LEXIS 171
CourtMichigan Supreme Court
DecidedJune 1, 1971
Docket8 October Term 1970, Docket No. 52,429
StatusPublished
Cited by24 cases

This text of 187 N.W.2d 411 (Hileman v. Indreica) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hileman v. Indreica, 187 N.W.2d 411, 385 Mich. 1, 1971 Mich. LEXIS 171 (Mich. 1971).

Opinions

Per Curiam.

This is an action under the dram-shop act (CLS 1961, § 436.22 [Stat Ann 1970 Cum Supp § 18.993]), brought by the surviving widow of one Hileman on behalf of herself and his minor [7]*7children. The jury’s verdict was no cause. Division 2 affirmed (15 Mich App 662). We granted leave (383 Mich 751) to examine anew what once was well settled evidentiary trial practice (Bresch v. Wolf [1928], 243 Mich 638; Higdon v. Kelley [1954], 339 Mich 209) but now seems to be GCR-muddled (Ruhala v. Roby [1967], 379 Mich 102).1

Today’s specific question arises during the direct or redirect examination of a witness whenever the examining counsel seeks to refresh or revive the witness’ memory by resort to some statement or document, the authenticity of which has been traced to the witness.

We examine first a venerably authoritative text and some of our own earlier cases in such regard. Jones tells us (5 Jones, Blue Book of Evidence [Bancroft-Whitney edition of 1914], headed “§ 883 [886]. Other modes of refreshing memory — Use of memoranda as evidence.” pp 330, 331):

“The expression ‘refreshing the memory’ is generally taken to refer to the stimulation of a witness’ memory by some written document such as we have hereinbefore particularly discussed. But it may be refreshed by other modes than the use of memoranda in writing. While a party cannot, as a rule, cross-examine his own witness, if a witness has given an ambiguous or indefinite answer, or if his memory is at fault, the court, in the exercise of a proper discretion, may allow verbal inquiry as to statements or circumstances which may tend to enable the witness to recollect more clearly the fact sought to be proved. It not infrequently happens [8]*8that a witness, under the embarrassment of an examination, forgets, or omits to state, facts within his knowledge, or is disinclined to disclose fully and definitely what he knows. Ample opportunity should be afforded for the correction of such mistakes and omissions, and for eliciting fully the facts that are material to the issue. The recollection of the witness may be so refreshed by directing his attention to a former conversation or declaration as to cause him promptly to correct his testimony or explain the apparent inconsistency. ‘A party who calls a witness, and is taken by surprise by his unexpected adverse testimony, may be permitted to interrogate him in respect to declarations and statements previously made by him which are inconsistent with his testimony, for the purpose of refreshing his recollection, and inducing him to correct his testimony, or explain his apparent inconsistency, and for such purpose his previous declarations may be repeated to him, and he may be called upon to say whether they were made by him.’ The purpose for which the questions are put — to refresh the witness’ memory — should clearly appear.”

This rule should startle no one. The purpose of all witness-examination is that of getting at the truth, and the rule which denies to the voucher of credibility all right of impeachment should not be stretched into denial of his right to call to the attention of the witness the latter’s previous statements, writings, affidavits or depositions which, upon the face or faces thereof, are apparently inconsistent with his trial testimony; the purpose and object being that of memory refreshment as set forth by Jones. Among our cases wherein this evidentiary practice has been upheld, on direct examination as well as cross-examination, are Beaubien v. Cicotte (1864), 12 Mich 459; Stone v. The Standard Life & Accident Insurance Company [9]*9(1888), 71 Mich 81; Prentis v. Bates (1891), 88 Mich 567; Pickard v. Bryant (1892), 92 Mich 430; People v. Case (1895), 105 Mich 92; People v. Palmer (1895), 105 Mich 568; People v. O’Neill (1895), 107 Mich 556; Dillon v. Pinch (1896), 110 Mich 149; People v. Johnson (1915), 186 Mich 516; Bresch v. Wolf, supra; Mitchell v. DeVitt (1946), 313 Mich 428, and Higdon v. Kelley, supra.

Admittedly, as in Bresch, the rule relating to the refreshment of a witness’ memory is largely one of judicial discretion. Yet as developed some 26 years later in Higdon, that discretion should be inclined toward properly controlled confrontation of the witness with his seemingly inconsistent recollection which upon oath has been recorded for depositional purposes. Consider the adoption, in Higdon, of quotations taken from Hickory v. United States (1894), 151 US 303, 309 (14 S Ct 334, 38 L Ed 170) and Bullard v. Pearsall (1873), 53 NY 230. Our conclusion was (Higdon at 219):

“This Court has held that prior statements may not be used when the sole purpose in their use is to impeach the credibility of a party’s own witness. See Farthing v. Hepinstall [1928], 243 Mich 380. But when the purpose of referring to the prior statement is to refresh the memory of a witness or to induce the witness to explain an apparent inconsistency, the prior statement may be referred to during direct examination.”2

The factual setting of present review is unique. The witness on the stand, called there by plaintiff, [10]*10was a Mrs. Hazel Burns. A year prior to the trial she had deposed in detail with respect to the pleaded issue of unlawful furnishing of intoxicating liquor to an allegedly intoxicated person, that is, to this plaintiff’s since deceased husband. No witness possibly could be in a better position than she to relate all of the facts upon which plaintiff’s charge of actionable violation of the dramshop act might turn. Furthermore, she herself had commenced a separate action against the same defendants, under the same statute, for personal injuries arising out of the same events. That action was pending at the time of her pretrial deposition. Of it, more later.

The summary disposition in circuit of plaintiff’s attempt at trial to employ Mrs. Burns’ deposition, and then of plaintiff’s effort to make a separate record by examining Mrs. Burns according to the deposition (see GCR 1963, 604), suggests that the trial judge did not read the deposition to determine the posed question of inconsistency. Instead, and erroneously in our view, the judge looked upon the effort of counsel solely as an attempt to impeach Mrs. Burns, or as an effort to have her judged “hostile.” His final ruling:

“The Court: This matter has been ruled upon by the court once, but I will rule again. This motion is a motion to utilize the deposition previously taken of the witness Hazel Burns. Now it’s an accepted rule of evidence in this State that a witness cannot — that a party cannot impeach his own wit[11]*11ness, and that is exactly what you are attempting to do by this use of the deposition.
“The rule which you quoted, Mr. G-oldstone, is not saying what you said it said.

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Hileman v. Indreica
187 N.W.2d 411 (Michigan Supreme Court, 1971)

Cite This Page — Counsel Stack

Bluebook (online)
187 N.W.2d 411, 385 Mich. 1, 1971 Mich. LEXIS 171, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hileman-v-indreica-mich-1971.