United States v. Catalan-Roman
United States Court of Appeals for the First Circuit
585 F.3d 453 (2009)
The federal government (plaintiff) prosecuted Lorenzo Catalan-Roman and Hernando Medina-Villegas (defendants) for an armored car robbery that led to the murder of a guard, Rodriguez; the government sought the death penalty for that killing. Torres, the armored car's driver, was wounded and briefly interviewed by police in the hospital, where he omitted aggravating details he later gave at trial showing Medina had acted with premeditation. The defense sought to introduce the hospital interview to suggest Torres had fabricated the trial details, but the judge excluded it as extrinsic evidence on a collateral matter. The jury convicted both defendants, and they were sentenced to life without parole. They appealed the exclusion of the hospital interview.
Whether extrinsic evidence offered to impeach a witness's trial testimony is admissible when it bears on a matter of consequence to the case, as opposed to a merely collateral matter.