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defendanttrialtestimonytrustcross-examinationadmissibilitycredibility
defendanttrialtestimonytrustwilljury trialcredibility

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Harris v. New York, 401 U.S. 222, 91 S.Ct. 643, 28 L.Ed.2d 1

Facts

The State of New York charged the defendant with selling heroin to an undercover police officer on two occasions. During the trial, the undercover officer testified about the sales, while the defendant admitted to knowing the officer but denied selling heroin, claiming instead that he sold baking powder. On cross-examination, the prosecution used statements made by the defendant to police after his arrest, which contradicted his trial testimony. The trial judge instructed the jury that these statements could only be considered for assessing the defendant's credibility.

At a subsequent jury trial the officer was the State's chief witness, and he testified as to details of the two sales. A second officer verified collateral details of the sales, and a third offered testimony about the chemical analysis of the heroin. Petitioner took the stand in his own defense. He admitted knowing the undercover police officer but denied a sale on January 4, 1966. He admitted making a sale of contents of a glassine bag to the officer on January 6 but claimed it was baking powder and part of a scheme to defraud the purchaser.

Issue

Whether a statement made by the defendant to police, which was inadmissible in the prosecution's case in chief due to lack of Miranda warnings, could be used to impeach the defendant's credibility during trial.

We granted the writ in this case to consider petitioner's claim that a statement made by him to police under circumstances rendering it inadmissible to establish the prosecution's case in chief under Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), may not be used to impeach his credibility.

Rule

A statement that is inadmissible against a defendant in the prosecution's case in chief due to lack of procedural safeguards may still be used for impeachment purposes if it satisfies legal standards of trustworthiness.

Statement inadmissible against a defendant in the prosecution's case in chief because of lack of the procedural safeguards required by Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694, may, if its trustworthiness satisfies legal standards, be used for impeachment purposes to attack the credibility of defendant's trial testimony.

Analysis

The court applied the rule by determining that the defendant's earlier statements, although inadmissible in the prosecution's case in chief, were relevant for impeachment because they contradicted his trial testimony. The court reasoned that allowing the use of such statements for impeachment purposes did not violate the principles established in Miranda v. Arizona, as it served to uphold the integrity of the judicial process by allowing the jury to assess the credibility of the defendant's testimony.

The impeachment process here undoubtedly provided valuable aid to the jury in assessing petitioner's credibility, and the benefits of this process should not be lost, in our view, because of the speculative possibility that impermissible police conduct will be encouraged thereby.

Conclusion

The court affirmed the conviction, concluding that the use of the defendant's prior statements for impeachment was appropriate and did not violate his constitutional rights.

Affirmed.

Who won?

The State of New York prevailed in the case, as the court upheld the conviction based on the reasoning that the impeachment of the defendant's credibility was justified despite the inadmissibility of the statements in the prosecution's case in chief.

The State's case against Harris depended upon the jury's belief of the testimony of the undercover agent that petitioner ‘sold’ the officer heroin on January 4 and again on January 6.

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