United States v. Havens
Citation and Court
446 U.S. 620 (1980) — Supreme Court of the United States
Facts
Havens was charged with cocaine importation. At trial he denied on direct examination that he had been involved in a scheme to smuggle drugs. The government sought to introduce illegally seized evidence — a T-shirt with makeshift pockets — to impeach his testimony on cross-examination. He argued the suppressed evidence could not be used for any purpose.
Issue
Whether illegally seized evidence that is inadmissible in the prosecution’s case-in-chief may be used to impeach a defendant’s testimony on cross-examination.
Holding
Yes; suppressed evidence may be used to impeach testimony made by the defendant on cross-examination that is fairly responsive to questions first raised by the defendant on direct examination.
Rule / Doctrine
The exclusionary rule does not bar the use of otherwise inadmissible evidence for impeachment when the defendant opens the door by testifying inconsistently on direct examination. The rule of Walder v. United States is extended to cross-examination that is responsive to the defendant’s direct testimony. Using suppressed evidence to impeach prevents defendants from committing perjury behind a constitutional shield.
Significance
Extended Walder to allow impeachment on cross-examination with suppressed evidence, not just to contradict voluntary statements on direct examination. A critical limitation on the exclusionary rule’s scope.