Bentley v. State

In Bentley v. State, 397 P.2d 976 (Alaska 1965), the Court held that it was error for a trial judge to exclude extrinsic evidence of a witness's prior inconsistent statement when (1) the crucial issue at trial was whether the jury should credit the witness's present testimony or should instead credit her prior inconsistent statement, and (2) the extrinsic evidence offered by the defendant -- an audiotape -- demonstrated the complete context of the witness's prior statement. (Bentley, 397 P.2d at 978.) For these reasons, the court concluded that there was a reasonable possibility that the jury would view the facts differently if they heard, not simply the witness's unelaborated concession that she had previously made inconsistent statements, but the tape of the conversation in which she had made those statements. (Id. at 978-79.)