United States v. Webster
Citation and Court
734 F.2d 1191 (7th Cir. 1984), United States Court of Appeals for the Seventh Circuit
Facts
Webster was convicted of a federal crime. At trial, the government sought to impeach him with a prior conviction. Webster challenged the admission of the prior conviction, arguing that the trial court failed to conduct the proper balancing required by FRE 609 before admitting the conviction to impeach his credibility.
Issue
Whether the trial court properly balanced the probative value of a prior conviction against its prejudicial effect before admitting it for impeachment under FRE 609.
Holding
The Seventh Circuit found that the district court had adequately considered the relevant factors and affirmed the conviction, while articulating the factors courts must weigh under FRE 609(a)(1).
Rule / Doctrine
Under FRE 609(a)(1), prior convictions for crimes punishable by more than one year may be admitted to impeach a witness if the court determines that the probative value of the evidence outweighs its prejudicial effect to the defendant. Relevant factors include: the nature of the conviction, its recency, the similarity to the charged offense, the importance of the defendant’s testimony, and the centrality of credibility.
Significance
United States v. Webster provides an important articulation of the multi-factor balancing test for admitting prior convictions under FRE 609(a)(1), and is frequently cited alongside Luce v. United States in teaching the law of impeachment by prior conviction.