United States v. Estrada

430 F.3d 606 (2005)

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United States v. Estrada

United States Court of Appeals for the Second Circuit
430 F.3d 606 (2005)

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Facts

Frank Estrada, Felix DeJesus, and others (defendants) were charged with various offenses relating to narcotics trafficking. During trial in federal district court, the United States (plaintiff) presented testimony from several cooperating witnesses. Defense counsel proposed impeaching some of the cooperators’ testimony with evidence of the cooperators’ prior convictions. The district court said that for “a conviction that goes to credibility,” defense counsel could inquire into the nature of the conviction. However, the court said that “[i]f it’s simply a felony conviction,” then defense counsel could ask about only the fact and date of the conviction without naming the offense. Using those guidelines, the court limited defense counsel to asking about the fact and date of unnamed felony convictions for cooperating witnesses who had been convicted of burglary, larceny, drug offenses, murder, robbery, escape, and manslaughter. DeJesus was convicted, and he appealed to the United States Court of Appeals for the Second Circuit.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

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