Kansas v. Ventris
Citation and Court
556 U.S. 586 (2009) — Supreme Court of the United States
Facts
Police planted an informant in a cell with Ventris, who was charged with murder. The informant elicited incriminating statements from Ventris in violation of his Sixth Amendment right to counsel. At trial, Ventris testified inconsistently with those statements, and the prosecution used the informant’s account to impeach him.
Issue
Whether a statement obtained in violation of the Sixth Amendment right to counsel may be used to impeach the defendant’s inconsistent trial testimony.
Holding
Yes; the Sixth Amendment-tainted statement is inadmissible as substantive evidence but may be used for impeachment purposes.
Rule / Doctrine
Consistent with the Fourth Amendment impeachment exception (U.S. v. Havens) and the Miranda impeachment exception (Harris v. New York), the Court held that the exclusionary remedy for Sixth Amendment violations does not bar use of the tainted statement to impeach a defendant who testifies inconsistently. The constitutional violation is complete at the moment of elicitation; the remedy is exclusion from the prosecution’s case-in-chief, not from all use.
Significance
Extends the impeachment exception to Sixth Amendment right-to-counsel violations, reinforcing that defendants who take the stand and lie cannot shelter behind constitutional violations to protect fabricated testimony.