United States v. Manske
United States Court of Appeals for the Seventh Circuit
186 F.3d 770 (1999)
Thomas Manske (defendant) was tried in federal district court for conspiracy to distribute cocaine. At trial, Stephen Pszeniczka and Daniel Knutowski testified that they received weekly deliveries of cocaine from Manske and that he was their primary supplier. The government’s case rested almost entirely on the testimony of these two witnesses. In defense, Manske asserted that he engaged in illegal gambling activities with Pszeniczka and Knutowski and that their weekly meetings were related to gambling. The government (plaintiff) moved in limine to prevent Manske from cross-examining Pszeniczka on threats of physical violence he made to witnesses in a related case and to prevent cross-examination of two other government witnesses regarding the threats made by Pszeniczka. Manske sought to show on cross-examination, based on Jeffrey Matter’s sworn statement to police, that Pszeniczka had threatened to kill Matter, if Matter did not change his story. Matter did change his story and Pszeniczka threatened Matter again in case Matter returned to his original story. Manske also wanted to show through cross-examination, and based on witness statements to police, that Pszeniczka had threatened Mary Colburn and Jackie Campbell, both of whom were government witnesses in Manske’s trial. Colburn was prepared to discuss finding in her yard dolls with nooses around their necks and a sign saying “Narcs live here,” and “You’re dead.” The government argued that the threats were not probative of truthfulness or untruthfulness and only showed “propensity for violence.” The district court granted the government’s motion in limine. Manske was convicted and appealed his conviction to the United States Court of Appeals for the Seventh Circuit, arguing that the district court erred by failing to admit the evidence regarding Pszeniczka’s threats under Federal Rule of Evidence (FRE) 608(b).
Rule of Law
Holding and Reasoning (Flaum, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 171,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.