Capital Defense Weekly
(correction)

Just a quick correction to the last edition.  I missed a case a rehearing in Soffar Dretke and inadvertently failed to double check the analysis provided by a commercial service in Black v. Missouri.  Additionally,  Black would have likely been spotlighted on the hotlist as it addresses a common issue contested  in trial courts (the scope of cross) but rarely addressed favorably by courts on appeal.

The correction, which will be added to the archives on Monday, will have the following correction.  Thanks to everyone (and I mean everyone) who brought these cases to my attention.
Soffar v. Dretke, 2004 WL 2636108 (5th Cir 11/19/2004) (on rehearing)  Clarifying the scope and authority of  a certificate of appealability.

Black v. Missouri, 2004 WL 2663641 (Mo 11/23/2004) Relief GRANTED on claims "trial counsel was ineffective in failing to impeach four witnesses with prior inconsistent statements that he argues showed that the murder was not the result of deliberation."


*5 [4] The State does not contest the trial court's finding that counsel's failure to impeach was not trial strategy. Nor does it argue the motion court's holding that the impeachment evidence was cumulative was correct. But, it does argue that the failure to impeach these witnesses was not prejudicial. This Court disagrees.

[5][6] As this and other courts have long recognized:

The trial court has broad discretion in determining the admissibility of substantive evidence and in determining the extent and scope of cross-examination, including impeachment of a witness by use of a prior inconsistent statement.

Long v. St. John's Regional Health Center, 98 S.W.3d 601, 605-06 (Mo.App. S.D.2003); Reno v. Wakeman, 869 S.W.2d 219, 223 (Mo.App. S.D.1993). The trial court's discretion is not unlimited, however. It must be balanced against the fact that, "[t]he right to cross-examination is essential and indispensable," State v. Jaynes, 949 S.W.2d 633 (Mo.App. E.D.1997), and "[t]he right to cross-examine a witness who has testified for the adverse party is absolute and not a mere privilege." Pettus v. Casey, 358 S.W.2d 41, 44 (Mo.1962); Doe v. Alpha Therapeutic Corporation, 3 S.W.3d 404, 423 (Mo.App. E.D.1999). For this reason, a trial judge "has no discretion to prevent any cross-examination at all on a proper subject," Merk v. St. Louis Public Service Co., 299 S.W.2d 446, 450 (Mo.1957), nor may that judge "exclude relevant and material facts simply because counsel seeks to elicit such facts on cross-examination." Long, 98 S.W.3d at 606, quoting Reno, 869 S.W.2d at 223.

[7][8][9][10] Missouri courts have harmonized these principles by holding that a judge cannot preclude a defendant from impeaching a prosecution witness with prior inconsistent statements if the impeachment does not concern an immaterial or collateral matter. State v. Dunson, 979 S.W.2d 237, 242 (Mo.App. W.D.1998). "A matter is considered to be collateral if the fact in dispute is of no material significance in the case or is not pertinent to the issues developed." Id. "In contrast, a matter is not collateral if the alleged discrepancy involves a crucial issue directly in controversy or relates to any part of the witness' account of the background and circumstances of a material transaction, which as a matter of human experience he would have been mistaken about if his story was true." Id. (internal quotations omitted). "If a fact may be shown in evidence for any purpose independent of contradiction, it is not collateral." State v. Goodman, 738 S.W.2d 470, 474 (Mo.App. W.D.1987). Furthermore:

As a general rule, a witness may be asked any questions on cross-examination that tend to test accuracy, veracity, or credibility, or shake the witness' credit by injuring his or her character. [citation omitted] Where a witness' prior inconsistent statement relates specifically to a paramount issue in the case, the trial court does not have discretion to prevent the impeachment of the witness through the use of that statement.

Long, 98 S.W.3d at 606.

[11] As applied here, this means the trial court would have had no authority to prevent impeachment of the State's witnesses on matters related to a paramount issue or that affected their accuracy, veracity, or credibility had counsel sought to do so. By their nature, such issues are not collateral.

[12][13][14] Nor, if not collateral, can the failure to offer this evidence be justified on the grounds that the evidence was cumulative, as the motion court found. It appears it so ruled because other witnesses had testified to Mr. Black's version of the incident. But, this does not make this evidence cumulative. "Evidence is said to be cumulative when it relates to a matter so fully and properly proved by other testimony as to take it out of the area of serious dispute." State v. Kidd, 990 S.W.2d 175, 180 (Mo.App. W.D.1999) (internal quotations omitted). While an appellate court will normally defer to a trial court's determination as to what evidence fits within this rule, a trial court does not have discretion to reject evidence "as cumulative when it goes to the very root of the matter in controversy or relates to the main issue, the decision of which turns on the weight of the evidence." Id. Accord, State v. Perry, 879 S.W.2d 609 (Mo.App. E.D.1994).

Perry is instructive as to how to apply the cumulative evidence rule. The State there argued that no prejudice resulted from the trial court's exclusion of internal police department records impeaching the credibility of some of the State's key witnesses to defendant's alleged confession, because defendant's sister testified to the events that would have been shown by the records. The court rejected this argument, stating:

It borders on the frivolous to contend that the testimony of defendant's sister, refuted on the stand by Briscoe, is equivalent to the transcript of Briscoe's statement to the police which stated the very things she denied stating on the stand. Evidence is not to be rejected as cumulative when it goes to the very root of the matter in controversy or relates to the main issue, the decision of which turns on the weight of the evidence.

Perry, 879 S.W.2d at 613.

The evidence defense counsel failed to offer here did not relate to "a matter so fully and properly proved by other testimony as to take it out of the areas of serious dispute." Kidd, 990 S.W.2d at 180. To the contrary, the impeaching evidence focused on the "very root of the matter in controversy." Perry, 879 S.W.2d at 613. The evidence of the prior inconsistent statements of Mr. Wolfe, Mr. Brandon, and Ms. Copeland related directly to the central issue of whether Mr. Black acted with deliberation or in a fit of rage or out of self-defense. As the fact that Mr. Black killed Mr. Johnson was conceded, this was the key issue in contention between the parties. Here, as in Perry, it borders on the frivolous to say that presenting defense witnesses as to how the killing occurred was the equivalent of showing that the State's key witnesses had previously agreed with all or part of defendant's recounting of that central, controverted fact. The weight of the evidence on this issue was central to the case.

*7 Even more basically, the un-offered prior inconsistent statements as to how the death occurred simply are not cumulative of any other evidence, even had they related to a collateral matter. For, while a number of witnesses testified to the events leading to the killing, what Mr. Black says should have been impeached with these prior statements was the accuracy of Mr. Wolfe's, Mr. Brandon's and Ms. Copeland's own perceptions of those events. No other witness had addressed the accuracy of these three witnesses' perceptions or showed that they had previously given inconsistent statements; indeed, no other evidence could more effectively have impeached their trial testimony than their own prior words. See Lagud v. Kansas City Board of Police Commissioners, 136 S.W.3d 786 (Mo. banc 2004) (prior admission of suspect impeaching his own trial testimony as to his intoxication could not by its nature be cumulative).

[15][16] Defense counsel also failed to impeach Mr. Martin with his prior statements showing that he, Mr. Wolfe, and the victim had been drinking far more heavily than Mr. Martin admitted on the stand. The State argues that this evidence, at least, was cumulative because other evidence was presented that showed that the victim, Mr. Johnson, had a .29 BAC at the time of his death. But, the State also continued to contest Mr. Johnson's intoxication, suggesting that the .29 BAC reading was an anomaly and that Mr. Martin's testimony that they only had a few beers was accurate. In this circumstance, it was ineffective to fail to introduce the prior statements tending to show more extensive drinking, for, "[i]t has long been the rule in Missouri that on cross-examination a witness may be asked any questions which tend to test his accuracy, veracity or credibility or to shake his credit by injuring his character." Lagud, 136 S.W.3d. at 793. Lagud further held that "intoxication of a witness as of the time the events took place which are the subject of the witness' testimony is not a collateral issue but bears directly upon the ability of the witness to accurately describe those events." Id. at 794. It was, therefore, a proper subject of impeachment and not excludable as cumulative or collateral.

IV. PREJUDICIAL EFFECT OF COUNSEL'S INEFFECTIVENESS
[17][18] In considering the prejudicial effect of movant's lawyer's ineffectiveness, "counsel's actions should be judged by her overall performance, the right to effective assistance of counsel may in a particular case be violated by even an isolated error of counsel if that error is sufficiently egregious and prejudicial." Deck, 68 S.W.3d at 429 (internal quotations omitted).

[19] The State argues that in order to prove prejudice, Mr. Black was required to have called each of the witnesses in question at his post-conviction motion hearing so that he could show what they would have stated had his counsel attempted to impeach them with their prior inconsistent statements. The court noted in rejecting a similar argument in Clay v. State, however, "[t]he 29.15 hearing is not a trial of the charges. Its purpose is to receive evidence touching on the adequacy of counsel's performance. The [witnesses'] testimony shows that important evidence was available if only counsel had looked for it." 954 S.W.2d 344, 348 (Mo.App. E.D.1997) (Blackmar, J.). In other words, a movant is not required to reenact how a hypothetical trial would have proceeded had particular evidence been utilized, but to show that counsel knew of the evidence and was ineffective in failing to use it, to movant's prejudice.

*8 Here, counsel's failures went to the key issue of deliberation. The record in this case shows that the jury was focused on that issue. The jurors circled the words "cool reflection" in the first-degree murder verdict director and sent the verdict director to the judge with a note stating, "Judge, please define this phrase ." The judge refused to do so, and directed the jury to be guided by the instructions. It returned a verdict of guilty.

A similar situation occurred in Deck, in which this Court had to determine whether error by counsel in failing to object to instructions to the jury regarding whether or not to impose the death penalty was so prejudicial as to require a new trial. In determining that a new trial was required, this Court considered how this missing instruction might have impacted the jury and concluded:

Most tellingly, the jurors ... sent the judge a note stating they were confused about what mitigation meant in Instruction 8 and asking for a legal definition of the term ... While the court's denial of their requests was proper, the requests show that the jury was focusing on the issue of mitigation and may have been confused by what it meant as used in the instructions.

68 S.W.3d at 431. Deck concluded that the failure was prejudicial.

As in Deck, when the jury here sent a note to the judge indicating confusion by circling the words "cool reflection" in the first-degree murder verdict director, the court did not err in refusing to define the term. Here also, the request shows that the jury was focusing on this issue and was confused by the evidence concerning deliberation.

That evidence was not overwhelming, consisting principally of testimony of State's witnesses who said Mr. Black reached into the truck and stabbed the victim. On direct appeal, the Court found that this evidence was sufficient to support the verdict. Had that testimony been impeached, little would have remained to support the finding of deliberation. [FN2] As noted in Clay:

The relative strength or weakness of the prosecution's case is significant in determining whether any deficiencies in trial counsel's performance were prejudicial, because the question which must be answered is whether, but for the deficiencies, the result of the trial might have been different.

954 S.W.2d at 346-47.

The unoffered evidence, admissible both for impeachment and as substantive evidence, went to a central, controverted issue on which the jury focused during deliberations. If believed by the jury, there is a reasonable probability that the outcome of the trial would have been different. Accordingly, this Court determines that counsel's ineffectiveness was so prejudicial as to undermine this Court's confidence in the outcome of the trial. The motion court therefore erred in overruling the motion for post-conviction relief under Rule 29.15. The judgment is reversed. Pursuant to Rule 84.14, a new trial is ordered on all issues. The case is remanded.