People v. Heckathorne

In People v. Heckathorne (1988) 202 Cal. App. 3d 458, the defendant was charged with a shotgun murder. During cross-examination, the prosecutor elicited from defendant that he had a prior conviction for assault with a deadly weapon, which was a car. Over a defense objection, the prosecutor was allowed to pursue the underlying circumstances and elicit the fact that the defendant had rammed his car into the victim's car and then chased after him. On appeal, the court reversed because these additional underlying facts were irrelevant and highly prejudicial, there was not overwhelming evidence of guilt on the charged offense, and thus the jury's determination was primarily on an impression of the defendant unfairly prejudiced by the irrelevant information. (Id. at pp. 461-463.) The defendant did not give potentially misleading testimony about the prior conviction on direct examination. The Heckathorne court explained that although the scope of inquiry when a criminal defendant is impeached with evidence of a prior felony conviction generally does not extend to the facts of the underlying offense, there is a well-settled exception where the defendant first seeks to mislead a jury or minimize the facts of the earlier conviction. (People v. Heckathorne, supra, 202 Cal. App. 3d at p. 462.)