State v. Felix, 103 A.3d 927

Defendant Felix was convicted of sale/delivery of 200 mg+ heroin after a jury trial in Rutland Superior Court, Criminal Division.
State’s key witness (informant) cooperated under a VD TF confidential-informant agreement with sentencing implications.
Informant purchased heroin in a controlled buy at Felix’s apartment; pat-downs occurred; initial testimony supported the conviction.
Later, informant’s vehicle was stopped; the traffic stop led to termination of her cooperation agreement due to alleged untruthfulness.
Informant testified at trial under a deferred-sentence condition requiring truthful testimony; Detective LaChance testified about the termination but not the stop incident firsthand.
Felix sought to introduce evidence that the termination followed the traffic stop to impeach credibility; the court limited cross-examination and barred certain termination-related evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the termination of the informant’s cooperation agreement was admissible to impeach credibility.	Felix argues termination shows bias/untruthfulness and should be fully explored.	LaChance’s termination and reasons are admissible to show motive and context.	Remand for new trial; termination evidence improperly restricted.
Whether Detective LaChance’s reasons for termination could be elicited on cross-examination.	Such questioning reveals credibility issues and the informant’s reliability.	Questions about termination are hearsay and should be limited.	Exclusion of certain questions and evidence was abused; reversal ordered.
Whether the termination statement itself was admissible as evidence or via Rule 608/404(b).	Termination statement provides proper context and motive for credibility.	Termination statement contains hearsay and is not admissible as extrinsic evidence.	Exclusion upheld as proper; but overall evidentiary rulings require new trial review.
Whether the State’s vouching by Detective LaChance affected the narrative and prejudiced Felix.	LaChance’s testimony about trust incorrectly framed credibility.	Any vouching was limited and not prejudicial.	Narrative skewing found; trial court reversible error.

Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (cross-examination to reveal witness bias under Confrontation Clause)
State v. Cartee, 161 Vt. 73 (Vt. 1993) (limits on cross-exam to reveal bias; Rule 404/608 interplay)
State v. Lawrence, 194 Vt. 315 (Vt. 2013) (confrontation and cross-examination balancing test)
John A. Russell Corp. v. Bohlig, 170 Vt. 12 (Vt. 1999) (interwoven evidence/context admissibility; risk of prejudice)
State v. Findlay, 171 Vt. 594 (Vt. 2000) (context evidence; informant misconduct cases; limitations on cross-exam)
State v. Fellows, 194 Vt. 77 (Vt. 2013) (harmless-error standard for appellate review)
State v. Johnson, 195 Vt. 498 (Vt. 2013) (jurisdictional deference to jury credibility determinations)