Derrick Lamont Riddle appeals his conviction, after a jury trial, on two counts of drug trafficking in violation of 21 U.S.C. § 841. He asserts that he was denied due process and a fair trial as a result of the cumulative effect of several trial errors. Specifically, Riddle asserts that the district court 2 erred in limiting his cross-examination of the government’s key witness and in prohibiting him from presenting several witnesses who could testify on the key witness’s reputation for truthfulness. We affirm.
1. BACKGROUND
The government’s case against Riddle was premised on two controlled buys of crack cocaine by an undercover Arkansas State Police Investigator, Willie Robinson. Robinson was the government’s only witness. Understandably, Riddle’s defense strategy was to attack Robinson’s credibility,
To that end, Riddle filed a motion for production of exculpatory evidence in police files, including information regarding “prosecutions [that had been] dismissed
The district court granted in part, and denied in part, the motions. First, the district court found Robinson’s personnel file to be inadmissible extrinsic evidence that related to the impeachment of a witness under Rule 608 of the Federal Rules of Evidence. It nevertheless ordered the government to advise Riddle in writing of any cases that had been dismissed due to Robinson’s mistakes or unreliability as well as to advise Riddle of all disciplinary actions against Robinson that involved dishonesty, mishandling of funds or any other matter reflecting on truthfulness or trustworthiness. The court also denied Riddle’s motion to sequester Robinson. Finally, it denied the government’s motion to exclude Carmen McMahan but noted that while it would “permit defendant to elicit testimony from a few competent witnesses regarding Robinson’s reputation or character for truthfulness or untruthfulness,” it would not allow “a parade of witnesses for this purpose.”
The case proceeded to trial and Riddle was allowed to cross-examine Robinson concerning several disciplinary actions and mistakes. Riddle also presented several witnesses who testified that Robinson had a reputation as a dishonest person who abused his position as a police officer. Carmen McMahan testified that Robinson forged her father’s name on a car title, stole evidence and “buy money,” and lost large sums of money gambling. The jury returned a verdict of guilty on both counts.
II. DISCUSSION
We review a trial court’s discovery orders very narrowly and uphold the district court’s discovery orders unless there was a “gross abuse of discretion resulting in fundamental unfairness in the trial of the case.”
Wilson v. Beloit Corp.,
A motion to sequester witnesses is similarly reviewed under an abuse of discretion standard “and should not normally be disturbed on appeal.”
United States v. Sykes,
Riddle asserts several other errors and contends that the cumulative effect of these errors rendered his trial unfair. We may reverse where the case as a whole presents an image of unfairness that has resulted in the deprivation of a defendant’s constitutional rights, even though none of the claimed errors is itself sufficient to require reversal.
See United States v. Steffen,
III. CONCLUSION
For the reasons set forth, the judgment of the district court is affirmed.
Notes
. The Honorable Elsijane Trimble Roy, United States District Judge for the Eastern District of Arkansas.
