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Keywords

defendanttrialdue processprosecutorcross-examinationcommon lawcredibility

defendanttrialcross-examinationcredibility

Related Cases

Doyle; U.S. v.

Facts

On August 13, 1974, the petitioner stabbed and killed Doyle Redding. The petitioner was not apprehended until he turned himself in to authorities about two weeks later. At his state trial for first-degree murder, he claimed self-defense, stating that Redding had attacked him with a knife after accusing him of informing the police about a robbery. During cross-examination, the prosecutor questioned the petitioner about his actions after the stabbing and alluded to his pre-arrest silence during closing arguments.

On August 13, 1974, the petitioner stabbed and killed Doyle Redding. The petitioner was not apprehended until he turned himself in to governmental authorities about two weeks later. At his state trial for first-degree murder, the petitioner contended that the killing was in self-defense.

Issue

Whether the use of pre-arrest silence to impeach a defendant's credibility violates the Fifth or Fourteenth Amendment.

The question in this case is whether the use of prearrest silence to impeach a defendant's credibility violates either the Fifth or the Fourteenth Amendment to the Constitution.

Rule

The Fifth Amendment guarantees the right to remain silent, but a defendant who testifies waives this right and can be impeached like any other witness. The Fourteenth Amendment's due process rights are not violated by the use of pre-arrest silence for impeachment, as this practice is traditionally allowed under common law.

The Fifth Amendment guarantees an accused the right to remain silent during his criminal trial, and prevents the prosecution from commenting on the silence of a defendant who asserts the right.

Analysis

The Court applied the rule by determining that since the petitioner voluntarily took the stand in his own defense, he was subject to cross-examination regarding his prior silence. The Court referenced previous cases, including Raffel v. United States, to support the notion that a defendant's decision to testify waives the right to remain silent. The Court concluded that the impeachment of the petitioner's credibility through his pre-arrest silence did not violate his constitutional rights.

Thus, the Raffel Court concluded that the defendant was 'subject to cross-examination impeaching his credibility just like any other witness.'

Conclusion

The Supreme Court affirmed the lower court's decision, holding that the use of pre-arrest silence to impeach a defendant's credibility does not violate the Constitution.

We hold that impeachment by use of prearrest silence does not violate the Fourteenth Amendment.

Who won?

The State prevailed in the case, as the Supreme Court upheld the lower court's ruling that the use of pre-arrest silence for impeachment purposes was constitutional.

The Court affirmed the denial of the prisoner's petition for federal habeas relief.

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