State v. Caldwell

Police officer Mark Meyer claimed he saw Phillip Caldwell (defendant) toss a bag during a police chase. The bag was located and found to contain illegal drugs. The only evidence that Caldwell had ever possessed the bag was Meyer’s claim. Caldwell was charged with illegal possession. At trial, Caldwell sought to introduce testimony from three witnesses that Meyer had a reputation for being untruthful. One witness was Caldwell’s father, who had heard comments from friends and family about their negative experiences with Meyer. Another witness was a college student who had heard four different people comment about Meyer being untruthful. The third witness was Ray Dial, a local teacher with strong ties to community organizations, including committees that received complaints about local police officers. Dial had heard comments about Meyer from numerous people in the community with varied backgrounds. These people either personally had had a bad experience with Meyer or knew a friend or family member who had encountered Meyers. The trial court found that all the testimony was based on comments from people who had had negative experiences with Meyers and that this was a limited group, not a general cross section of the community. The trial court then excluded the reputation testimony as limited and unreliable. Caldwell was convicted and appealed. On appeal, Caldwell argued that the trial court erroneously focused on the comments’ nature instead of their source.