## Facts

- Alford was prosecuted in federal court for using the mails to defraud under the federal mail-fraud statute.
- The government called a former employee who gave damaging testimony about transactions and conversations with Alford, including matters not corroborated by other witnesses.
- On cross-examination, defense counsel asked the witness where he lived to identify him and to lay a foundation for credibility testing.
- The trial court sustained the government’s objection and barred inquiry into the witness’s residence as “immaterial” and outside proper cross-examination.
- Outside the jury’s presence, defense counsel proffered that the witness was in federal custody and that this could show bias, prejudice, fear, or expectation of favor.
- The trial court maintained the restriction, allowing inquiry into a felony conviction but not detention in custody.
- The court of appeals affirmed, reasoning the trial judge had discretion and a duty to protect witnesses from discrediting evidence unless reasonably required.

## Issues

1. Whether a criminal defendant is entitled, as a matter of right, to cross-examine a key government witness about basic identifying information, including residence.
2. Whether the trial court abused its discretion by foreclosing inquiry that could reveal bias based on the witness’s detention by federal authorities.
3. Whether the restriction on cross-examination was prejudicial error requiring reversal of the conviction.

## Decision

- The Supreme Court reversed the judgment affirming the conviction.
- Cross-examination is a matter of right and includes identifying the witness with his environment and exposing facts that could discredit testimony.
- The question “Where do you live?” was a proper preliminary question and an initial step toward a permissible bias inquiry.
- By cutting off, in advance, all inquiry into a subject on which the defense was entitled to reasonable cross-examination, the trial court committed an abuse of discretion.
- The error was prejudicial because the witness’s credibility was central and the defense was denied a meaningful opportunity to test it.

## Legal Principles

- Cross-examination of a witness in a criminal case is a matter of right.
- Proper cross-examination includes (1) identifying the witness with his environment and (2) revealing facts tending to discredit the witness’s testimony, including bias or motive.
- A cross-examiner generally need not disclose the purpose of a line of inquiry as a precondition to asking proper cross-examination questions.
- Trial courts have discretion over the scope of cross-examination, but that discretion is exceeded when a reasonable line of inquiry into credibility and bias is wholly barred.
- A court may prevent questioning that merely harasses, annoys, or humiliates a witness, but it has no duty to shield a witness from legitimate impeachment, absent a properly invoked privilege against self-incrimination.

## Conclusion

The Supreme Court set aside the conviction because the trial court’s categorical limitation on cross-examination—preventing inquiry into the witness’s residence and potential custody-based bias—denied the defense a reasonable opportunity to test the credibility of an important prosecution witness.


Alford v. United States, 282 U.S. 687 (1931)