Hazelett v. State

Summary

The Court affirmed Hazelett’s convictions, holding that the trial court constitutionally and appropriately limited cross-examination of the chief investigating officer under the applicable four-factor impeachment analysis. The court also held that the trial court properly barred argument that the traffic stop was illegal, while allowing Hazelett to challenge whether the State proved the turn-signal violation. Although the trial court improperly suggested that defense counsel had to disclose impeachment material before cross-examination, the error was harmless because the jury heard substantial impeachment evidence and the officer’s testimony was corroborated.