Facts
- A safe containing over $1,000 in cash and checks was stolen from the Polar Bar near Anchorage, Alaska.
- The safe was later found outside Anchorage near the home of Jess Straight.
- Straight’s stepson, Richard Green, told police he saw two Black men near a blue Chevrolet in the area where the safe was later found.
- Green identified Joshaway Davis in a lineup as one of the men he claimed to have seen.
- At the time of trial, Green was on juvenile probation after a delinquency adjudication for burglary.
- The prosecution obtained a protective order barring defense cross-examination about Green’s juvenile adjudication and probation status under state juvenile-confidentiality provisions.
- The defense sought to question Green about probation status to show potential bias and motive to cooperate with police or deflect suspicion from himself.
- The trial court prohibited the inquiry, and the jury heard Green as a seemingly disinterested citizen-witness.
Issues
- Whether the Sixth Amendment Confrontation Clause (as applied to the states) requires allowing cross-examination of a prosecution witness about juvenile probation status to show possible bias, despite state confidentiality rules for juvenile records.
Decision
- The Supreme Court reversed and remanded.
- The Court held that the restriction violated the Confrontation Clause by preventing effective cross-examination aimed at exposing a key witness’s possible bias.
- The Court ruled that the state’s interest in protecting juvenile confidentiality must yield when it blocks disclosure necessary to present a concrete theory of bias to the jury.
Legal Principles
- The Confrontation Clause secures a defendant’s right to cross-examine prosecution witnesses, including inquiry designed to reveal bias, motive, or partiality.
- Bias impeachment differs from general character impeachment; a defendant may probe facts showing a witness’s vulnerability to police pressure or incentive to shift suspicion.
- A trial court violates the Confrontation Clause when it allows only generalized questions about bias but bars the underlying facts needed for the jury to evaluate that bias.
- State evidentiary or confidentiality policies, including juvenile-record protections, cannot be applied to materially impair a defendant’s ability to expose a prosecution witness’s possible bias.
Conclusion
The Court held that the Sixth and Fourteenth Amendments required permitting cross-examination into a key witness’s juvenile probation status when offered to show bias or motive, and that juvenile-confidentiality interests could not justify shielding the jury from facts necessary to assess the witness’s credibility.