STEVEN CHADWICK, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Steven Chadwick was convicted of battery on a law enforcement officer and resisting arrest with violence. The appellate court reversed because the trial court improperly excluded evidence of the officers' bias—specifically, that Chadwick had threatened to sue them and they were subjects of an internal investigation he initiated.
The trial court improperly excluded evidence relevant to the bias of the state's witnesses. The internal investigation and threatened suit against the deputies were admissible because they were clearly relevant to show the officers' potential bias against the appellant when testifying at trial, regardless of when the underlying events occurred.
[1] A defendant has a Sixth Amendment right to a full and fair opportunity to cross-examine prosecution witnesses to show bias or motive to be untruthful.
[2] A defendant may offer additional evidence to show the bias of prosecution witnesses.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The Sixth Amendment, as incorporated into the Fourteenth Amendment, guarantees a defendant in a state criminal prosecution the right to a full and fair opportunity to cross-examine prosecution witnesses in order to show their bias or motive to be untruthful.”
Establishes the constitutional foundation for the right to impeach witness bias through cross-examination
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Join FLexlaw to unlock all legal intelligenceChadwick was charged with battery on a law enforcement officer and resisting arrest with violence. After his arrest, he filed a complaint against the …
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ALLEN, Judge.
The appellant challenges' his convictions for battery on a law enforcement officer and resisting arrest with violence. Because the trial court improperly excluded evidence relevant to the bias of the state’s witnesses, we reverse.
The appellant was charged with battery on a law enforcement officer and resisting arrest with violence. He thereafter filed a complaint against the deputies involved in his arrest alleging that they used excessive force in placing him into a cell upon arrival at the jail. An internal investigation was conducted, and the deputies were aware that the appellant had threatened to file a civil suit against them. The trial court precluded any cross-examination of-the officers or other trial testimony relating to the internal investigation or threatened suit against the officers.
The Sixth Amendment, as incorporated into the Fourteenth Amendment, guarantees a defendant in a state criminal prosecution the right to a full and fair opportunity to cross-examine prosecution witnesses in order to show their bias or motive to be untruthful. Olden v. Kentucky, 488 U.S. 227, 109 S.Ct. 480, 102 L.Ed.2d 513 (1988); Delaware v. Van Arsdall, 475 U.S. 673, 106 S.Ct. 1431, 89 L.Ed.2d 674 (1986); Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974); Mosley v. State, 616 So. 2d 1129 (Fla. 3d DCA 1993); Caton v. State, 597 So. 2d 412 (Fla. 4th DCA 1992). And a defendant also has the right to offer additional evidence to show the bias of prosecution witnesses. See § 90.608(2), Fla. Stat. (1993); see also Diaz v. State, 597 So. 2d 368 (Fla. 3d DCA 1992). Therefore, when a prosecution witness is under internal investigation for the incident which gave rise to the charges against a defendant, or when there is a pending civil suit or criminal charge against the witness arising out of the incident, those matters may be inquired into on cross-examination or developed in the defense ease. Mosley; Catón; Diaz.
The state argues that the threatened suit and pending internal investigation in this case were irrelevant because they grew out of events at the jail some time after the arrest. We find this argument unpersuasive. It is true that the events at the jail occurred after the appellant’s arrest, but that does not change the fact that the appellant had threatened to sue the deputies and that they were the subjects of an internal investigation initiated by the appellant. The internal investigation of the deputies and the threatened suit against them were clearly relevant to the question of their bias against the appellant when they testified at trial.
Because this ease involved a classic swearing match between the deputies and the defense witnesses, we cannot say that the improper exclusion of the impeachment evidence was harmless beyond a reasonable doubt. See State v. DiGuilio, 491 So. 2d 1129 (Fla.1986).
The appellant’s conviction is reversed and the case is remanded.
MINER and MICKLE, JJ., concur.
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Wyon Dale Childers v. State, 936 So. 2d 585 (Fla. 1st DCA 2006)…o away” in exchange for money); • McBean v. State, 688 So. 2d 383, 385 (Fla. 4th DCA 1997) (finding the trial court erred in not allowing cross-examination of State witness with regard to omission made in pretrial statements); • Chadwick v. State, 680 So. 2d 567, 568 (Fla. 1st DCA 1996) (finding the trial court erred in excluding evidence of appellant’s threatened lawsuit and internal investigation regarding police abuse arising after appellant’s arrest); • Livingston v. State, 678 So. 2d 895, 898 (Fla. 4t…
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Barows v. State, 805 So. 2d 120 (Fla. 4th DCA 2002)…as well as the Sixth Amendment to the United States Constitution, guarantee a defendant “the right to a full and fair opportunity to cross-examine prosecution witnesses in order to show their bias or motive to be untruthful.” See Chadwick v. State, 680 So. 2d 567, 568 (Fla. 1st DCA 1996) (citations omitted). Patently, “[a] defendant has a strong interest in discrediting a crucial state’s witness by showing bias, an interest in the outcome, or a possi [*123] ble ulterior motive for his in-court testimony.” Au…
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Ford Michael v. State, 884 So. 2d 83 (Fla. 2d DCA 2004)…ing this possible motive. Moreover, because this case came down to a “swearing match” between Michael’s version of events and the officer’s version, we cannot say the trial court’s error was harmless beyond a reasonable doubt. See Chadwick v. State, 680 So. 2d 567 (Fla. 1st DCA 1996). Accordingly, we reverse and remand for a new trial. CASANUEVA and WALLACE, JJ, Concur.…
Previewing 3 of 9 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. DiGUILIO, 491 So. 2d 1129 (Fla. 1986)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986)
- Olden v. Kentucky, 488 U.S. 227 (U.S. 1988)
- Mosley v. State, 616 So. 2d 1129 (Fla. 3d DCA 1993)
- Caton v. State, 597 So. 2d 412 (Fla. 4th DCA 1992)
- Diaz v. State, 597 So. 2d 368 (Fla. 3d DCA 1992)