## Facts

- Paul Green, a county prisoner in a work-release program, was injured at work when his arm was torn off after he reached into an industrial dryer to stop it.
- Green sued the machine’s manufacturer, Bock Laundry Machine Company, in a civil products liability action alleging defects caused his injury.
- At trial, Bock impeached Green on cross-examination with evidence of Green’s prior felony convictions for burglary and a related offense.
- Green moved before trial to exclude the felony convictions; the district court denied the motion under Federal Rule of Evidence 609(a)(1).
- The jury returned a verdict for Bock, and the Third Circuit affirmed.

## Issues

1. In a civil case, does Federal Rule of Evidence 609(a)(1) require admission of a witness’s prior felony convictions for impeachment without regard to unfair prejudice to the witness or the party calling the witness?
2. If Rule 609(a)(1) applies, may the trial court nonetheless exclude the conviction evidence under Rule 403 due to unfair prejudice?

## Decision

- The Supreme Court affirmed the judgment for Bock.
- The Court held that, under the then-existing text of Rule 609(a)(1), prior felony convictions used to impeach a civil witness “shall be admitted” without balancing unfair prejudice to that witness or the party offering the testimony.
- The Court further held that Rule 403 could not be used to exclude such impeachment evidence because Rule 609(a)(1) operated as a specific, mandatory command in this setting.
- The district court therefore did not err by allowing impeachment of Green with his felony convictions.

## Legal Principles

- Under the pre-amendment version of Federal Rule of Evidence 609(a)(1), the phrase “prejudicial effect to the defendant” was construed to protect only an accused in a criminal case, not civil parties or civil witnesses.
- In civil trials, felony-conviction impeachment evidence falling within Rule 609(a)(1) was mandatory and could be admitted even if it created substantial unfair prejudice to the civil witness or the party who called the witness.
- When a specific evidentiary rule mandates admission of a defined category of evidence, general Rule 403 discretion does not permit exclusion based on unfair-prejudice balancing in conflict with that mandate.

## Conclusion

The Court interpreted Rule 609(a)(1) to require automatic admission of prior felony convictions for impeachment of civil witnesses and to displace Rule 403 exclusion based on unfair prejudice to the civil witness or the party presenting the witness.


Green v. Bock Laundry Mach. Co., 490 U.S. 504 (1989)