United States V, Abel 469 U.S. 45, (1984).
Facts:
Abel, Ehle, and Mills were arrested for bank robbery. Ehle, decided to falsely testify against Abel in return for a lighter sentence in connection to the robbery.
Procedural Posture:
In the case of United States V. Abel, Abel was the defendant in the case and was charged in connection with a bank robbery. One of his accomplice in the robbery was caught by the name of Ehle and he had agreed to testify against Abel in the case. As the trial got underway Abel decided that he would rebut Ehle’s testimony based on the testimony of Mills whom has stated that Ehle’s decided to forge his testimony about the robbery to have his sentence reduced. After this took place the prosecution decided to call Ehle’s back to the stand to rebut this claim by establishing Ehle’s, Able, and Mills were a part of a prison gang that denies the existence and commit perjury for one another. Based on this informations the district court admitted the testimony and convicted Abel. Abel’s council decided to appeal before the US court of appeals 9th circuit court and Abel conviction was overturned.
Issues:
Evidence tending to show a bias based on a party to the case acting as a witness is inadmissible if the informations tends to show that the defendant was telling a lie.
Is a district court accorded a wide discretion in determining the admissibility of evidence under the federal rules?
Holdings:
Yes. A district court is accorded a wide discretion in determining the admissibility of evidence under the federal rules.
Reasoning: [1]. In this case the membership of Mills in the prison gang was sufficiently probative of Mills’ possible bias towards Abel to warrant its admission, and was within the discretion of the trial court. Although the rules do not expressly refer to the admissibility of extrinsic evidence to show bias, this evidence is otherwise covered by 402’s allowance of “relevant” evidence. Proof of bias is relevant, and...