Alford v. United States

282 U.S. 687 (1931)

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Alford v. United States

United States Supreme Court
282 U.S. 687 (1931)

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Facts

The United States government (plaintiff) prosecuted Alford (defendant) for mail fraud. One of Alford's former employees testified against him at trial. At the time, the witness was being detained on felony criminal charges. On cross examination, Alford's lawyer asked the witness where he lived in an attempt to elicit testimony regarding the witness’s detention, and consequently, to explore whether being in custody created any bias or gave the witness any incentive to give false testimony. However, the judge excluded the question as immaterial and improper. The judge reasoned a witness's felony conviction might be material to the witness’s credibility, but mere detention on criminal charges would not. The jury convicted Alford, and the appeals court upheld the conviction. On appeal to the United States Supreme Court Alford argued it was reversible error to disallow questioning of the employee about his residence.

Rule of Law

Issue

Holding and Reasoning (Stone, J.)

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