Hall v. State

Supreme Court of Wyoming · 2005 · Evidence

109 P.3d 499 (Wyo. 2005)

Updated August 22, 2026

EvidenceW.R.E. 608(b)bias impeachmentextrinsic evidenceself-interestharmless errorW.R.E. 404(b)limiting instruction

Facts

Hall was charged with conspiring with or aiding Brenda Schriner and Todd Harnden in operating a clandestine methamphetamine laboratory set up in Hall's home. Schriner and Harnden had entered plea agreements and pleaded guilty to operating a different clandestine laboratory, and Schriner testified for the State against Hall. Hall sought to call John David Parker and Jim Mikolash to testify that Schriner had previously threatened or falsely accused others of drug-related crimes to advance her own interests. The district court excluded that testimony as extrinsic evidence under W.R.E. 608(b) and as not particularly relevant.

Issue

Did the district court err by excluding testimony that Schriner had previously threatened or falsely accused others to serve her own self-interest, on the ground that it was extrinsic evidence under W.R.E. 608(b)? Did the court also err in its W.R.E. 404(b) limiting instruction or in allowing testimony about Schriner's guilty plea?

Rule

W.R.E. 608(b) bars extrinsic evidence only when it is offered to prove a witness's general character for truthfulness or untruthfulness. It does not bar extrinsic evidence offered to show a witness's bias, interest, or self-interest, because such evidence is relevant to motive to slant testimony. Even when such evidence is wrongly excluded, reversal is not required if the jury nonetheless had sufficient information to make a discriminating appraisal of the witness's possible motives for testifying falsely.

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In a burglary trial in Cheyenne, the prosecution's key witness, Dana Keel, testified under an agreement that she hoped would help her avoid prison on unrelated theft charges. The defense wants to call Omar Velez to testify that, months earlier in Casper, Dana threatened to report him for drug dealing unless he paid for repairs to her truck.

The prosecutor objects that Omar's testimony is inadmissible extrinsic evidence of a specific bad act under Rule 608(b). How should the court rule?

Explanation. Rule 608(b) bars extrinsic evidence only when it is offered to prove a witness's general character for truthfulness or untruthfulness. It does not bar extrinsic evidence offered to show bias, interest, or self-interest motivating testimony. Omar's account tends to show that Dana uses accusations to advance her own interests, which supports the defense theory that she may be shading her testimony to gain favorable treatment.