Davis v. Alaska

In Davis v. Alaska, 415 U.S. 308 (1974), the defendant was charged with a burglary involving the theft of a safe. (Id. at pp. 309-311.) The key prosecution witness was a juvenile, who testified he saw the defendant near where the abandoned safe was found. (Id. at pp. 309-310.) Although the juvenile was on probation for burglary, the trial court barred the defendant from cross-examining him regarding whether his probation had motivated him to make an ill-founded identification of defendant, either because he hoped to shift suspicion away from himself, or because the police had applied undue pressure to him. (Id. at p. 311.) The United States Supreme Court held that the ruling contravened the defendant's confrontation rights, as it prevented him from raising a significant inference of witness bias. (Id. at pp. 316-321.) In Davis, the defendant was charged with a burglary involving the theft of a safe. (Davis, supra, 415 U.S. at pp. 309-311.) The key prosecution witness was a juvenile, who testified he saw the defendant near where the abandoned safe was found. (Id. at pp. 309-311.) Although the juvenile was on probation for burglary, the trial court barred the defendant from cross-examining him regarding whether his probation had motivated him to make an ill-founded identification of the defendant, either because he hoped to shift suspicion away from himself, or because the police had applied undue pressure to him. (Id. at p. 311.) The United States Supreme Court held that the ruling contravened the defendant's confrontation rights, as it prevented him from raising a significant inference of witness bias. (Id. at pp. 316-321.) In Davis v. Alaska, the defendant, on trial for grand larceny and burglary, sought to introduce evidence of the juvenile record of a critical prosecution witness. The defense claimed the witness's probationary status as a juvenile delinquent subjected him to undue pressure from the police, leading to a faulty pretrial identification of the defendant and a tainting of the witness's in-court identification. The Supreme Court held that the Sixth Amendment right to confront witnesses required that Davis be allowed to challenge the witness with evidence of a possible motive for his alleged misidentification. ( Davis, supra, at p. 317.) The defendant was not allowed to ask the crucial prosecution witness questions about a prior prosecution that would have revealed his bias and motive to fabricate evidence against the defendant. The United States Supreme Court held that this restriction impermissibly infringed on the defendant's right to confront and cross-examine the witness. ( Id. at p. 311.) The Davis Court held the trial court's failure to allow defense counsel to question the witness about his probationary status violated the defendant's Sixth Amendment right "to be confronted with the witnesses against him." Id. at 315, 39 L. Ed. 2d at 353. Thus, in both Davis the State exerted power over the witnesses because they were either presently facing charges or the loss of their probationary status.