## Facts

- The defendant was tried in Georgia for voluntary manslaughter and related offenses arising from a homicide.
- At trial, the defendant testified in his own defense.
- During direct examination, the defendant stated he had “never been in trouble before.”
- The prosecution sought to introduce evidence of the defendant’s prior assault conviction to rebut that testimony and impeach his credibility.
- The trial court admitted the prior conviction for impeachment/rebuttal purposes, and the defendant was convicted.

## Issues

1. Whether the defendant’s testimony that he had “never been in trouble before” permitted the State to introduce a prior assault conviction to impeach that testimony.
2. Whether admitting the prior conviction constituted reversible evidentiary error in the prosecution for voluntary manslaughter and related crimes.

## Decision

- The Court of Appeals affirmed the convictions.
- The court held that the defendant’s sweeping claim of having “never been in trouble” placed his character and prior history in issue to that extent.
- The trial court did not err by allowing the State to rebut and impeach the testimony with evidence of the prior assault conviction.

## Legal Principles

- A defendant who testifies may be impeached when he makes an unqualified, misleading assertion about his past (e.g., claiming he has never been in trouble).
- When a defendant “opens the door” with broad testimony about prior conduct, the State may introduce otherwise inadmissible rebuttal evidence limited to correcting the false or misleading impression.
- Appellate review of such evidentiary rulings focuses on whether the challenged evidence was a proper rebuttal to the specific testimony elicited and whether its admission was within the trial court’s discretion.

## Conclusion

The court upheld the defendant’s voluntary manslaughter and related convictions, concluding that his testimony that he had “never been in trouble before” allowed the State to impeach and rebut that statement by introducing a prior assault conviction.


Walker v. State, 260 Ga. App. 241, 581 S.E.2d 295 (Ga. Ct. App. 2003)