United States v. Lindstrom

Dennis Slater and Joanne Lindstrom (defendants) were charged with fraud due to their roles in a therapy company that allegedly defrauded insurance companies. At trial, the prosecution’s primary witness was a former employee of Slater and Lindstrom’s therapy company. She testified that she discussed alteration of patient insurance records with Slater and Lindstrom, that she and Lindstrom had in fact altered patient records, and that Slater and Lindstrom had ordered her to duplicate billing cards and had ordered patients to sign up for treatments they did not receive. In their cross-examination of the witness, Slater and Lindstrom sought to show that the witness’s motive for initiating the investigation of the company and for her testimony was hatred of and a vendetta against Slater and Lindstrom. Slater and Lindstrom sought to question the witness about various actions that had resulted from her psychiatric illness, including the following: she offered a patient of the therapy company $3,000 to shoot the wife of the witness’s lover; she attempted to shoot a shotgun through the window of her lover’s house, after which she was involuntarily committed; and she had attempted suicide for the purpose of manipulating and punishing her boyfriend. Slater and Lindstrom claimed that by introducing evidence of her psychiatric history, they were attempting to show the witness’s behavioral pattern of manipulative and spiteful conduct toward people close to her. The trial court excluded much of Slater and Lindstrom’s line of questioning, including questions regarding the actions listed above. The trial court found Slater and Lindstrom guilty. Slater and Lindstrom appealed on the ground that the trial court’s limitation of their cross-examination of the witness violated their Sixth Amendment right to confront a witness against them.