United States v. Urena
United States Court of Appeals for the Ninth Circuit
659 F.3d 903 (2011)
- Written by Sean Carroll, JD
Facts
Lenny Urena (defendant) and Gary Dennis got into a fight while in prison. Dennis sustained lacerations in the fight, and a shank was recovered from Urena. Urena confessed to possessing the shank but later stated that he only confessed so he would not be deemed a snitch. Urena was charged for his role in the fight. At trial, the prosecution (plaintiff) called Dennis’s treating physician, Dr. Jaime David. David testified about the nature of Dennis’s injuries. The prosecution filed a motion seeking to prevent Urena from asking David about causation of Dennis’s injuries. The district court granted the motion on the ground that the prosecution did not open the door by asking David about causation on direct examination. The district court held that examination about causation was outside the permitted scope of Urena’s cross-examination because it was different than examination about the nature of the injury. Urena was, however, permitted to cross-examine David about any bias he had. Urena was convicted, and he appealed, arguing that the ruling violated his rights under the Confrontation Clause.
Rule of Law
Issue
Holding and Reasoning (Gould, J.)
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