## Facts

- Ralph Dean Bradford was indicted for first-degree murder arising from a fatal shooting; he claimed self-defense.
- The State presented three eyewitnesses whose accounts supported guilt and conflicted with self-defense.
- The defense presented David Earl Trammell as the only eyewitness supporting Bradford’s self-defense account.
- On cross-examination, Trammell admitted he previously told Officer Troy Tate he was not present at the shooting.
- On redirect, the defense sought to elicit Trammell’s explanation that he denied being present because he feared Tate, a law officer and a relative of the deceased.
- The trial court sustained the State’s objection and excluded Trammell’s explanation.
- The jury convicted Bradford of first-degree manslaughter, and Bradford appealed.

## Issues

1. Whether, after impeachment by a prior inconsistent statement, a witness may explain the circumstances and motive for the inconsistency, including fear of an investigating officer related to the victim.
2. Whether excluding such explanatory testimony was prejudicial error requiring reversal.

## Decision

- The Alabama Court of Appeals reversed and remanded for a new trial.
- The trial court erred by preventing Trammell from explaining why he made the prior inconsistent statement.
- The error was prejudicial because Trammell’s credibility was central in a case turning on conflicting eyewitness accounts and self-defense.

## Legal Principles

- When a witness is impeached by a prior inconsistent statement, the proponent may elicit the circumstances under which the statement was made, including motives that induced it, to rehabilitate credibility.
- Testimony describing the witness’s own state of mind (including fear) is admissible when offered as explanatory context for an impeaching statement, rather than as substantive proof of a disputed ultimate fact.
- Excluding explanatory rehabilitation evidence is reversible where credibility is critical and the limitation likely affected the verdict.

## Conclusion

Because the prosecution impeached the defense’s key eyewitness with a prior inconsistent statement, fundamental fairness required allowing the witness to explain that the inconsistency resulted from fear of the investigating officer who was related to the victim; barring that explanation materially impaired the defense and warranted reversal and remand.


Bradford v. State, 90 So. 2d 96 (Ala. Ct. App. 1956)