US v. Byers: Byers and Co-Defendant Goodman were convicted of conspiracy and murder of a witness, Carl Lackl, to prevent Lackl from testifying in a Maryland state murder trial. On appeal, the two challenged several evidentiary rulings, and Goodman appealed the denial of his pretrial motion to suppress. The Fourth Circuit affirmed.
Lackl was to testify as an eyewitness against Byers in the March 2006 shooting of Larry Haynes; another eyewitness recanted, leaving Lackl as the sole person who could place Byers at the Haynes murder scene. Whether Byers had motive to kill and whether Lackl was accurate in his identification of Byers in the earlier murder investigation became crucial at trial.
The Fourth Circuit determined that 404(b) evidence of Byers's invovled in two prior shootings suggested a common theme, and was "necessary" to counter Byers's strategy of negating motive. And, for good measure, even if the district court abused its discretion in allowing this evidence in, the Fourth Circuit found this error was harmless. Byers attacked Lackl's reliability as an effective witness and Lackl's identification of Byers at the scene of Haynes's murder. Also, the Fourth Circuit held that it was not error to admit the statements of Lackl's girlfriend, who warned him of the mortal danger of his involvement as a testimonial witness.
Goodman's appeal issues concerned the testimony of a rebuttal witness, arguing that the proposed testimony failed to counter any new evidence presented in Goodman's case-in-chief. The Fourth Circuit decided that the proposed testimony went to the witness's credibility, and any error in admitting it was harmless. Goodman also appealed the denial of his motion to suppress of his post-arrest statements, which he claimed were involuntary. Under a totality of the circumstances, the Fourth Circuit found no unconstitutional coercion on the record.
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