United States v. Graham
2:23-cr-20588
E.D. Mich.Jun 23, 2025Background
- Deandre Graham is charged as a felon in possession of ammunition following a shooting incident.
- The incident involved Graham allegedly firing at Eric Mitchell-Rodgers and his girlfriend, R.M., after an argument; R.M. was seriously injured.
- Both Graham and Mitchell-Rodgers initially faced state criminal charges, but only Graham remains charged federally; Mitchell-Rodgers’s state charges were dismissed.
- At trial, the government will call R.M. to testify, but not Mitchell-Rodgers.
- Graham moved pretrial (in limine) to be allowed to cross-examine R.M. about Mitchell-Rodgers’s prior felony and dismissed charges to show possible bias.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Cross-examination on prior felony conviction | Irrelevant; R.M. implicated both men, not biased | Necessary to show R.M.'s bias & motive to protect boyfriend | Denied unless R.M.'s testimony shields Mitchell-Rodgers at trial |
| Cross-examination on dismissed state charges | Irrelevant & prejudicial to jury | Indicates possible bias, motive to shift blame | Denied; risks unfair prejudice and jury confusion |
Key Cases Cited
- Davis v. Alaska, 415 U.S. 308 (1974) (right to cross-examine witness for potential bias)
- United States v. Abel, 469 U.S. 45 (1984) (bias evidence generally admissible to show credibility challenges)
- Delaware v. Van Arsdall, 475 U.S. 673 (1986) (trial judges have discretion to limit cross-examination)