State v. Recor
In State v. Recor, 150 Vt. 40, 549 A.2d 1382 (1988), a witness alleging that her step-father had sexually assaulted her had been instructed not to mention a previous incident of alleged assault.
On cross-examination, the defense suggested that the witness was biased against the defendant and had been for some time.
Due to that attack, the court permitted the State to elicit information about the earlier assault to explain that the witness's bias was reasonable. See id. at 45, 549 A.2d at 1386.
The witness then testified that she had hated the defendant for several years because he had sexually assaulted her in 1982.
There, "defense counsel sought to impeach the credibility of the ... witness by painting an incomplete picture of unwarranted bias. The State's response was to complete this picture with appropriate detail. The purpose of the witness's testimony on redirect, thus, was not to establish the character of the defendant ..." Id. at 44, 549 A.2d at 1386.