State v. Gardner

433 A.2d 249, 139 Vt. 456
CourtSupreme Court of Vermont
DecidedJuly 21, 1981
Docket376-79
StatusPublished
Cited by52 cases

This text of 433 A.2d 249 (State v. Gardner) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Gardner, 433 A.2d 249, 139 Vt. 456 (Vt. 1981).

Opinions

Billings, J.

The defendant was charged with breaking and entering in the nighttime, in violation of 13 V.S.A. § 1201. The only defense presented was diminished capacity due to voluntary intoxication. The defendant alleged that he wished to testify at his trial about what he remembered and what he could not remember on the night in question. This testimony would have related to his defense of diminished capacity. The defendant made a motion in limine to prevent the State from using the defendant’s prior convictions for impeachment if he chose to testify on his own behalf. The defendant specifically requested the exclusion of a previous conviction for breaking and entering in the nighttime. The trial court denied the motion, holding that under 12 V.S.A. § 1608, and this Court’s decision in State v. Manning, 136 Vt. 436, 392 A.2d 409 (1978), the State as a matter of right could cross-examine the defendant about his earlier convictions. After the hearing on [458]*458the motion in limine, the defendant chose not to testify. The defendant was convicted after a jury trial, and now appeals.

In State v. Manning, supra, this Court held that a witness may be impeached by cross-examination concerning any prior convictions for crimes involving moral turpitude within 15 .years. The Court also held that the trial court has no discretion to exclude this form of impeachment. The defendant now asks this Court to overrule Manning, and hold that the impeachment of a witness by prior convictions is limited by the trial court’s discretion. The State’s position is that this case is controlled by 12 V.S.A. § 1608 and that section was correctly interpreted in Manning.

Upon reconsideration we conclude that Manning was decided incorrectly, ahd hold that the cross-examination of a witness concerning prior convictions is subject to the discretion of the trial court.

The fact that a witness has been convicted of certain crimes is generally thought to be relevant to the question of that witness’s credibility, Gordon v. United States, 383 F.2d 936, 940 (D.C. Cir. 1967), cert. denied, 390 U.S. 1029 (1968); People v. Sandoval, 34 N.Y.2d 371, 314 N.E.2d 413, 357 N.Y.S.2d 849 (1974), although there is disagreement about which crimes are relevant. C. McCormick, Evidence § 43, at 85 (Cleary ed. 1972). When the defendant in a criminal case testifies, he may generally be impeached to the same extent as any other witness. Brown v. United States, 356 U.S. 148 (1958). Impeachment by showing prior convictions, however, is generally recognized to be extremely prejudicial to the defendant in a criminal case. C. McCormick, supra, at 89. Despite limiting instructions a jury is likely to conclude that a defendant with a criminal record is a criminal by nature and likely to be guilty of the offense presently charged. Commonwealth v. Bighum, 452 Pa. 554, 307 A.2d 255 (1973); C. McCormick, supra. Or the jury may conclude that the defendant is a person.who deserves punishment regardless of his guilt of the offense charged. People v. Fries, 24 Cal. 3d 222, 594 P.2d 19, 155 Cal. Rptr. 194 (1979). C. McCormick, supra. If the defendant decides not to testify to prevent the jury from learning of his criminal record, the jury may take his silence as an indication of guilt. Id.

[459]*459In deciding that the State may cross-examine any witness about prior criminal convictions the Court in Manning did not discuss this dilemma faced by an accused who wishes to testify in his own behalf. This Court relied on earlier cases that had stated that the impeachment of witnesses by showing prior convictions was a matter of right. Pond v. Carter, 126 Vt. 299, 229 A.2d 248 (1967); State v. Russ, 122 Vt. 236, 167 A.2d 528 (1961). This had been repeated in a number of Vermont cases dating back to McGovern v. Hays, 75 Vt. 104, 53 A. 326. (1902). In each of these cases, however, this language was dictum. None of these cases prior to Manning addressed the question of the court’s discretion to exclude impeachment by a prior conviction, nor did any case attempt to analyze the language of 12 V.S.A. § 1608, the statute the State asserts is controlling in the case at hand.

12 V.S.A. § 1608 provides in relevant part: “The conviction of a crime involving moral turpitude within fifteen years shall be the only crime admissible in evidence given to affect the credibility of a witness.” The State argues that because of the word “shall” in this section the use of prior convictions to impeach a witness is a matter of right. We believe the section has a different meaning, however. In stating that certain convictions “shall be the only crime admissible to affect the credibility of a witness,” the statute is establishing the outer boundary of admissibility. Under this section, no crime may be admitted to impeach a witness unless it meets certain conditions; that is, it must involve moral turpitude, and the conviction must have been within 15 years. The effect is to remove from the trial court all discretion to admit crimes that do not meet these conditions. State v. Russ, supra, 122 Vt. at 238, 167 A.2d at 529. 12 V.S.A. § 1608, however, does not state that crimes that meet these conditions must always be admitted. To describe a certain category of evidence as admissible does not mean that the trial court is without discretion to exclude that evidence under some circumstances. Evidence which is otherwise admissible may be excluded if it is prejudicial, Quazzo v. Quazzo, 136 Vt. 107, 386 A.2d 638 (1978); State v. Davis, 132 Vt. 290, 318 A.2d 664 (1974), or because of delay, waste of time or cumulative effect. See Whitmore v. Mutual Life Insurance Co., 122 Vt. 328, 173 A.2d 584 (1961).

[460]*460In Quazzo v. Quazzo, supra, this Court stated as a general rule: “Although relevant, evidence may be excluded on the ground that its probative value is overwhelmed by its probable improper prejudicial effect.” Id. at 110, 386 A.2d at 640. In the absence of a statute requiring the admission of prior convictions to impeach a witness, this general rule should apply. In other jurisdictions without such a statute, most courts have held that a trial court has the discretion to prohibit the impeachment of a witness by evidence of prior convictions. See, e.g., People v. Beagle, 6 Cal. 3d 441, 492 P.2d 1, 99 Cal. Rptr. 313 (1972); State v. Bitting, 162 Conn. 1, 291 A.2d 240 (1971); Burrell v. State, 42 Md. App.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Venessa Sarkisian-Kennedy
2020 VT 6 (Supreme Court of Vermont, 2020)
State v. Jason Atherton a/k/a Melton
2016 VT 25 (Supreme Court of Vermont, 2016)
State v. Brewer
2010 VT 110 (Supreme Court of Vermont, 2010)
State v. White
182 Vt. 510 (Supreme Court of Vermont, 2007)
State v. Martin
2007 VT 96 (Supreme Court of Vermont, 2007)
State v. Setien
795 A.2d 1135 (Supreme Court of Vermont, 2002)
DeButts v. Laroche
711 A.2d 877 (Supreme Court of New Hampshire, 1998)
State v. Brown
676 A.2d 350 (Supreme Court of Vermont, 1996)
Johnson v. State
629 So. 2d 708 (Court of Criminal Appeals of Alabama, 1993)
State v. Ashley
623 A.2d 984 (Supreme Court of Vermont, 1993)
State v. Goodrich
564 A.2d 1346 (Supreme Court of Vermont, 1989)
State v. Larose
554 A.2d 227 (Supreme Court of Vermont, 1988)
State v. Hurley
552 A.2d 382 (Supreme Court of Vermont, 1988)
Fontaine v. District Court of Vermont
547 A.2d 1362 (Supreme Court of Vermont, 1988)
Richelson v. Richelson
536 A.2d 176 (Supreme Court of New Hampshire, 1987)
State v. Catsam
534 A.2d 184 (Supreme Court of Vermont, 1987)
State v. Emerson
541 A.2d 466 (Supreme Court of Vermont, 1987)
State v. Trask
533 A.2d 1185 (Supreme Court of Vermont, 1987)
State v. Brunelle
534 A.2d 198 (Supreme Court of Vermont, 1987)
State v. Savo
556 A.2d 54 (Supreme Court of Vermont, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
433 A.2d 249, 139 Vt. 456, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-gardner-vt-1981.