Woodward v. Commonwealth

LAMBERT, Chief Justice,

dissenting.

The majority has held that knowledge of Woodward’s removal from office upon conviction could not be used to impeach a principal witness for the- Commonwealth. Due to the potential for such evidence to reveal an improper motive for the witness, Woodward’s political opponent, to testify against him, I believe exclusion of this evidence to have been prejudicial error.

Appellant was convicted of a misdemeanor. Ordinarily the only available penalty for a misdemeanor conviction is confinement in the *482county jail for up to twelve months and a monetary fine. Upon this misdemeanor conviction, malfeasance in office, there is the additional sanction of removal from office. Removal from office upon conviction readily invites testimony against an accused that might be politically motivated. Thus, where there are consequences outside of the ordinary penalty structure, it would be only reasonable and fair to allow witnesses to be questioned for impeachment purposes regarding their knowledge of the extraordinary consequences. Such information is vital to the jury in assessment of credibility. See Holt v. Commonwealth, Ky., 259 S.W.2d 463, 465 (1953) (witness may be cross-examined regarding any facts showing bias or hostility towards the party against whom he is called); Keller v. Commonwealth, Ky., 572 S.W.2d 157, 159 (1978) (the jury is entitled to hear all the relevant facts that might have an influence on a witness’ testimony so that the jury may “properly estimate the weight to be given the witness’ testimony”); Williams v. Commonwealth, Ky., 569 S.W.2d 139, 145 (1978) (“the right to cross-examine a witness to impeach his credibility is fundamental to a fair trial”).

With removal from office as a statutory consequence, the magnitude of improper motivation it could reveal is tremendous. In the case at bar, the credibility of witnesses testifying against Woodward could not be properly evaluated by the jury without an inquiry into their knowledge of the extraordinary sanction of removal from office.

STUMBO, J., joins this dissenting opinion.