United States v. Hickey
United States Court of Appeals for the Sixth Circuit
917 F.2d 901 (6th Cir. 1990)
Quinn Hickey (defendant) was tried for conspiracy to distribute cocaine, and the prosecution's key witness, Jack Ventimiglia, admitted on cross-examination that he was a cocaine addict with a poor memory and gave testimony containing several inconsistencies. The district court nonetheless admitted his testimony, and Hickey was convicted. Hickey appealed, arguing Ventimiglia's addiction and memory problems meant he failed to meet the personal-knowledge requirement of Federal Rule of Evidence 602.
Whether a witness's admitted drug addiction and memory problems require excluding the witness's testimony for lack of personal knowledge under Federal Rule of Evidence 602.