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State v. Guenther
New Jersey Supreme Court
854 A.2d 308 (2004)
Kenneth Guenther (defendant) had a stepdaughter, DF, who falsely accused a neighbor of sexual abuse. DF later accused Guenther of sexual assault. Guenther was charged with sexual assault and related crimes, but he denied the charges. At trial, the primary issue was which person, DF or Guenther, was telling the truth. Guenther sought to introduce evidence of DF’s prior false accusation to impeach her credibility. The trial court ruled that the proposed impeachment evidence was extrinsic evidence of a prior bad act and excluded it under Rule of Evidence 608(b). Guenther was convicted and appealed. On appeal, Guenther argued that evidence of a prior false accusation was so relevant to a witness’s credibility that it should be an exception to Rule 608(b) and admissible to impeach a witness’s credibility.
Rule of Law
Holding and Reasoning (Albin, J.)
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