Case Brief: United States v. Abel
Facts
The case encompasses Abel and two cohorts who were accused of taking part in a bank robbery. However, Abel’s co-accused pleaded guilty while he went on trial. Ehle, one of the cohorts, testified against Abel but Abel countered his testimony with a witness, Mills, who had spent time with both Abel and Ehle in prison. Mills testified that Ehle had confided to him that he wanted to implicate Abel falsely to earn favor from the government. The prosecutor attempted to discredited Mills testimony by pointing out, through Ehle’s testimony that Mills, Ehle, and Abels belonged to a secret gang when they were in prison, called “Aryan Brotherhood,” and that the group required its members to deny its existence. Additionally, the gang was said to perpetrate crimes such as theft, perjury, and murder on behalf of its members. On the ohther hand, the defense counsel objects to this type of rebuttal testimony and points out that it is merely prejudicial to respondent (Buckles, 2017).
Issue
The court needed to decide whether Ehle’s rebuttal testimony’s probative value outweighed its prejudicial effect to be used to show that Abel was guilty.
Decision
The district court ruled that Ehle’s rebuttal testimony carried a probative value that outweighed its prejudicial effect leading to the conviction of Abel.
Discussion
The court took into consideration Mill’s and the respondent’s membership in the “Aryan Brotherhood” prison gang and its stipulations of denial. It court concluded that Mill’s testimony might have been compromised because of his allegiance to the group. Hence it couldn’t be admitted into evidence (Buckles, 2017). The court, citing Alford v. the United States, 282 U.S. 687 (1931) showed that it had a right to effectively cross-examine a witness to find out if there was any possibility of bias. The implication of Mills’ testimony being termed as biased was that it could not be used to prove that Abel wasn’t guilty of the crime that he was accused to have committed with his cohorts. At the end of the trial, Abel was convicted (Buckles, 2017).
Reference
Thomas Buckles (2017). Laws of evidence. Cengage Learning