State v. Stapp, 338 P.3d 772

Defendant and victim (Johnson) were drinking; Johnson put defendant in a headlock and struck him; defendant then stabbed Johnson eight times, causing serious injury. Defendant claimed self-defense.
At trial defendant testified on cross-examination that he had "never stabbed anyone before."
Prosecutor asked about a prior, unrelated incident in which defendant threatened a bicyclist with a knife; defense objected to using that incident to impeach the "never stabbed" statement.
Trial court allowed limited questioning about the bicyclist incident; defendant admitted he had threatened or swung a knife previously (but denied stabbing anyone).
Court of Appeals held the bicyclist incident was not proper impeachment of defendant’s precise factual statement that he had never stabbed anyone, so admission was error, but the error was harmless given the undisputed violent facts and the self-defense issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prior uncharged misconduct (bicyclist incident) was admissible to impeach defendant’s testimony that he had never stabbed anyone	State: defendant’s statement opened the door; prior incident rebutted a misleading impression that defendant had never used his knife violently	Defendant: the prior incident did not contradict the precise factual statement that he had never stabbed anyone and thus was improper character evidence	The evidence was not proper impeachment because it did not contradict the specific factual statement; admission was error but harmless
Whether erroneous admission requires reversal	State: impeachment corrected jury misperception about defendant’s violent past, affecting credibility/self-defense analysis	Defendant: admission invited impermissible inference of violent character and could have influenced verdict	Error was harmless given defendant’s admission of stabbing and the central issue being reasonableness of force; conviction affirmed

State v. Manrique, 271 Or. 201 (1975) (other acts may be used to impeach witness credibility)
State v. Smith, 86 Or. App. 239 (1987) (impeachment by contradictory evidence of specific factual testimony allowed)
State v. Grey, 175 Or. App. 235 (2001) (other-act evidence admissible only if independently relevant for a noncharacter purpose)
State v. Rood, 118 Or. App. 480 (1993) (impeachment by contradiction requires reasonably precise target statement)
State v. Hayes, 117 Or. App. 202 (1992) (ambiguous or imprecise statements are not proper targets for contradiction impeachment)
State v. Johnson, 277 Or. 45 (1977) (limits on eliciting collateral facts on cross to then introduce extrinsic impeachment evidence)