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Impeachment Evidence Character for Truthfulness


On appeal from his conviction of felony domestic assault, appellant argued that the District Court abused its discretion by denying his request at trial to play, in their entirety, two audio recordings of telephone conversations between him and the victim. The Court of Appeals noted that it was difficult to see how allowing the jury to listen to the audio recordings would be probative of the victim’s character for truthfulness when the recordings were primarily in Russian and untranslated, and there were no allegations that the substance of what was said conflicted with the victim’s trial testimony. The Court of Appeals concluded that the recordings were not proper impeachment evidence, and the District Court did not abuse its discretion by refusing to play the recordings in their entirety. Affirmed.

A14-1728 State v. Cam (Polk County)


Impeachment Evidence Opportunity to Explain


On appeal from his conviction of second-degree assault and theft of a motor vehicle, appellant argued that he was entitled to a new trial because the District Court erred by denying his request to call a witness to testify about the victim’s prior inconsistent statement regarding the nature and extent of her injuries from the assault. The Court of Appeals held that the District Court did not abuse its discretion by excluding extrinsic evidence of the witness’s prior statement because the witness was never afforded the opportunity to explain or deny the prior statement. Affirmed.

A14-1889 State v. Williams (Hennepin County)

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