Woodall v. United States

RUIZ, Associate Judge,

concurring:

I write separately to make clear that the prosecutor did not fulfill his duty in this case. I concur with the disposition of this case because I agree that, considering the evidence as a whole, there was no prejudice to appellant that would require reversal. Our affirmance is due to the ruling of the trial judge that permitted defense counsel to bring to light during' cross-examination of Detective Hamann evidence that flatly contradicted and corrected a material falsehood that had been presented by Russell, an important government witness who identified appellant as the robber and murderer during the government’s casé in chief. In coming to the conclusion that reversal is not required in a case where the prosecutor did not correct testimony he knew to be false, it is key that the correction came from a witness the jury would view as representing the government’s position. Were it not for defense counsel’s questioning and the answer it elicited, the government would have “permitted] false evidence,'known to be false, to go uncorrected,” see Keys v. United States, 767 A.2d 255, 261 (D.C.2001), and the jury would have retired to deliberate over evidence that contained a significant lie relevant to the credibility of a critical witness in the case. Because there would have been a reasonable likelihood that false evidence tainted the jury’s verdict, we would have .had to reverse. See Hawthorne v. United States, 504 A.2d *703580, 589-90 (D.C.1986) (citing Giglio v. United States, 405 U.S. 150, 154, 92 S.Ct. 763, 31 L.Ed.2d 104 (1972)). Such a result not only would have violated appellant’s due process rights, but also needlessly imperiled the interest of our criminal justice system in assuring sound convictions that will withstand challenge on appeal.

The Constitution’s Due Process Clause is violated if a conviction is obtained because the government knowingly used false evidence or “allow[ed] it to go uneor-rected.” Napue v. Illinois, 360 U.S. 264, 269, 79 S.Ct. 1173, 3 L.Ed.2d 1217 (1959); Hawthorne, 504 A.2d at 589 (citing Giglio, 405 U.S. at 153, 92 S.Ct. 763). Because in a jury trial the jury is the exclusive finder of fact and arbiter of guilt, it is ultimately the jurors — not the judge or defense counsel — who are “entitled to know” of false testimony that might affect a witness’s credibility. Giglio, 405 U.S. at 155, 92 S.Ct. 763; Napue, 360 U.S. at 269, 79 S.Ct. 1173. The “responsibility and duty to correct [a known falsehood] and elicit the truth” lies with the prosecutor. Napue, 360 U.S. at 269, 79 S.Ct. 1173 (quoting People v. Savvides, 1 N.Y.2d 554, 154 N.Y.S.2d 885, 136 N.E.2d 853, 854 (1956)); see also Giglio, 405 U.S. at 154, 92 S.Ct. 763 (“whether the nondisclosure was the result of negligence or design, it is the responsibility of the prosecutor”). In this case, the prosecutor took the necessary first step in discharging that responsibility by disclosing to the trial judge and to defense counsel that Russell had testified falsely, but he did not take the further steps necessary to “elicit the truth” for the jury. Quite the opposite, he improperly tried to block the defense’s efforts to bring the true facts to the jury’s attention: he refused a defense offer to enter into a joint stipulation on what the prosecutor had already agreed were the correct facts; interposed a questionable argument against the defense’s request for an admission of a party opponent; objected to defense counsel’s effort to cross-examine Detective Hamann on the subject on the ground that it was irrelevant even after the trial judge had already ruled to the contrary; and, though he agreed that the witness had committed perjury, objected to the defense request for the standard instruction on evaluating the testimony of an admitted perjurer.1

These efforts by the defense were intended to correct Russell’s untruthful testimony by bringing before the jury the fact that Russell falsely denied giving information to Detective Hamann about a separate shooting committed by Shank and falsely denied expressing his fear of Shank, who, according to Russell, was “armed to the teeth.” This was important information for the jury to consider because Shank was the person who the defense contended had committed the murder in this case. The defense’s theory was not improbable because Shank — the son of the co-perpetrator identified by the eyewitness to the murder in this case — appeared to fit the description of a man seen leaving the store immediately after the murder. The defense argued that because Russell was so afraid of Shank, Russell purposely misidentified appellant as the person who *704committed this crime instead of correctly identifying the fearsome Shank. The prosecutor did not at any time dispute that Russell had in fact accused Shank of another shooting in his conversation with Detective Hamann or that Russell was afraid of Shank, yet he interposed objection after objection to defense counsel’s various proposals to correct Russell’s false testimony. The prosecutor’s primary objection was irrelevance. This insubstantial objection was easily and correctly rejected by the judge early in the trial. See Winfield v. United States, 676 A.2d 1, 4 (D.C.1996) (en banc). But, as the majority opinion points out, the prosecutor persisted in this objection even after the trial judge had overruled it.2 And even after defense counsel’s cross-examination of Detective Hamann exposed that Russell’s denial of his conversation with the Detective was a lie, the prosecutor did not stand squarely behind what he knew to be the correct version when he last addressed the jury in rebuttal, but rather, suggested that Russell’s credibility on the issue was a question for the jury.3

A good prosecutor should press hard to obtain a conviction he believes is warranted by the evidence, but once the prosecutor knows that the government’s case is tainted with false evidence that could be material to the jury’s verdict, the constitutional imperative requires that the prosecutor’s zeal yield to his duty to ensure that the false evidence is corrected and the truth clearly presented to the jury. Cf. Berger v. United States, 295 U.S. 78, 88, 55 S.Ct. 629, 79 L.Ed. 1314 (1935) (explaining that the state’s interest “in a criminal prosecution is not that it shall win a case, but that justice shall be done”). That did not happen in this case, where the course of the prosecution — if not overcome by defense counsel and the trial court — would have “allow[ed a material falsehood] to go uncorrected.” Napue, 360 U.S. at 269, 79 *705S.Ct. 1173. If the prosecutor does not take the situation in hand to effectively correct the testimony before the jury, then, at a minimum, he should not obstruct the efforts of others who would do so. The fact that defense counsel and the trial judge ensured that the jury had the necessary correction enables us to affirm the conviction, but it should not obscure the prosecutor’s failure in this case to fulfill his constitutional responsibility to ensure the fundamental fairness of the trial.

. Thus, this is not a case, such as Bruce v. United States, 617 A.2d 986 (D.C.1992), cert. denied, 507 U.S. 1042, 113 S.Ct. 1878, 123 L.Ed.2d 496 (1993), where neither the prosecutor nor defense counsel did anything despite the fact that both already knew that the particular testimony at issue was false in light of FBI tests. See id. at 993. Even in that case, where we said that "it was at least arguably appropriate for the prosecutor to leave it to defense counsel to propose a way to protect the interests of his client,” id. at 993, we suggested that "it may well have been prudent” for the prosecutor to be proactive. See id. at 992. Applying plain error review, we affirmed the conviction.

. The prosecutor's other objections were weak, to say the least. While acknowledging that Russell had lied when he denied having talked to Detective Hamann about Shank, the prosecutor objected to disclosing Russell’s actual statements to Detective Hamann because they had been given "in confidence." The prosecutor objected to the request for admission on the ground that the government was not a party-opponent. But see Harris v. United States, 834 A.2d 106, 118 (D.C.2003) (citing Freeland v. United States, 631 A.2d 1186 (D.C.1993)).

. The prosecutor argued in closing that Russell had greater cause to fear appellant, who had cursed at him during the trial and some years earlier had robbed and threatened him at gun point, and that it did not make sense to say that Russell did not want to implicate Shank in the murder out of fear when Russell had been willing to implicate Shank's mother. The prosecutor did not, however, acknowledge Russell's conversation with Detective Hamann that he feared Shank. In her closing argument, defense counsel emphasized Russell's fear of Shank, as evidenced by his denial of the conversation with Detective Hamann, in an effort to create reasonable doubt about Russell’s motivation in identifying appellant as the murderer in this case. On rebuttal, the prosecutor did not concede the truth of Detective Hamann's testimony that Russell was afraid of Shank. Instead, the prosecutor told the jury that Detective Hamann testified about "the context” of Russell's conversation with him, inviting the jury to decide whether Russell had expressed a fear of Shank in his conversation with Detective Hamann. The prosecutor also mischar-acterized the defense's argument, saying that the defense wanted to "have it both ways” in its evaluation of Russell's credibility. The defense was not attempting to have it "both ways,” as its contention was that Russell had lied on the stand both when he denied talking to Detective Hamann about Shank and when he identified appellant as the murderer. It was Detective Hamann's testimony that Russell had told him about fearing Shank — which the prosecutor had told the court was the truth — that defense counsel argued to the jury should be credited in evaluating Russell's identification and trial testimony.