United States v. Manske

Thomas Manske (defendant) was tried for cocaine-distribution conspiracy based almost entirely on the testimony of two witnesses, Pszeniczka and Knutowski, who said Manske was their regular cocaine supplier; Manske countered that their meetings were actually about illegal gambling. The government successfully moved to bar Manske from cross-examining Pszeniczka, or two other government witnesses, about documented threats Pszeniczka had made — including threatening to kill a witness who might not cooperate, and threatening two other government witnesses whose yard was later found with nooses and a "Narcs live here...You're dead" sign. Manske was convicted and appealed, arguing this excluded evidence was admissible under Rule 608(b) as bearing on Pszeniczka's truthfulness, especially given the substantial sentence reduction Pszeniczka received for testifying.