Utah Supreme Court
State v. Biel
April 1, 2021484 P.3d 1172
Summary
The Utah Supreme Court reversed the district court’s interlocutory order denying the State’s motion in limine. It held that Utah Rules of Evidence 607 and 801(d)(1)(A) permit the State to call witnesses and admit their prior inconsistent statements both for impeachment and as substantive evidence, and that the State did not invite the district court’s error. The decision also remanded for further proceedings.
Holding
- Whether the district court erred in interpreting Utah Rules of Evidence 607 and 801(d)(1)(A) to exclude prior inconsistent statements as substantive evidence.. The district court misinterpreted the rules; the State may call the witnesses and admit their prior inconsistent statements both for impeachment and as substantive evidence.
- Whether the State invited the district court’s error in interpreting those rules.. The State did not invite the error; the district court’s error was not the result of an independent affirmative misrepresentation by counsel.
Docket Case No. 20191055
Cited authorities
- Fed. R. Evid. 801(d)(1)(A)
- Fed. R. Evid. 801(d)(1)(A)