Davis v. Alaska Case Brief

Why is the case important?

A crucial prosecution witness to in a robbery trial was a juvenile with a record of delinquency. The defendant sought to impeach the witness.

Facts of the case

Question

Whether the Confrontation Clause requires that a defendant in a criminal case be allowed to impeach the credibility of a prosecution witness by cross-examination directed at possible bias deriving the witness’ probationary status as a juvenile delinquent when such impeachment would conflict with a State’s asserted interest in preserving the confidentiality of juvenile adjudications of delinquency.

Answer

Yes. The Supreme Court of the United States first reiterated the basic premise of the Confrontation Clause, that an accused has the right to be confronted with the witnesses against him. The Supreme Court further examined the necessity of cross-examination, with special emphasis on the value of impeachment by introducing a prior criminal conviction. By so doing the cross-examiner intends to afford the jury a basis to infer that the witness’ character is such that he would be less likely than the average trustworthy citizen to be truthful in his testimony. In the present case, the Supreme Court found that while petitioner’s counsel was permitted to ask Green whether he was biased, counsel was unable to make a record from which to argue why Green might have been biased or otherwise lacked that degree of impartiality expected of a witness at trial. The Supreme Court suggested that the jury had no means of understanding the basis of this argument. The Supreme Court
conceded that the State did have an important interest in protecting the anonymity of juvenile offenders. It disputed, however, the argument that the need for anonymity outweighed any competing interest this petitioner might have in cross-examining Green.

Conclusion

The Supreme Court held that, in the circumstances presented, the Sixth and Fourteenth Amendments conferred the right to cross-examine the prosecution witness about his delinquency adjudication for burglary and his status as a probationer. Such cross-examination was necessary in order to show the existence of possible bias and prejudice. The Court disagreed with the state supreme court’s interpretation of the Confrontation Clause and the adequacy and meaningfulness of the scope of cross-examination required under it.

  • Case Brief: 1974
  • Petitioner: Davis
  • Respondent: Alaska
  • Decided by: Burger Court

Citation: 415 US 308 (1974)
Argued: Dec 12, 1973
Decided: Feb 27, 1974