Davis v. Alaska

Background

A defendant was tried for burglary and grand larceny after a safe stolen from a bar was found near a family property. A teenage neighbor, Richard Green, identified the defendant in a photo array, a lineup, and at trial. At the time Green made his initial identification he was on juvenile probation after a delinquency finding for cabin burglaries. The trial court barred the defense from revealing Green’s juvenile adjudication under Alaska rules protecting juvenile records.

Reasoning

The Court considered whether the Sixth Amendment’s right to confront witnesses requires allowing cross-examination that would disclose juvenile probation status to show possible bias. The majority stressed that cross-examination is essential to test a witness’s truthfulness and that showing a witness’s possible motive or pressure to help the prosecution is highly relevant. The Alaska Supreme Court had said the limited questioning allowed was adequate, but the High Court found that the defense was prevented from making the factual record needed to argue bias and reversed the conviction.

Real world impact

The decision means criminal defendants can, in similar circumstances, probe a witness’s juvenile probation to challenge identification testimony. States’ confidentiality rules for juvenile records remain important, but they cannot block effective cross-examination; a state may avoid disclosure only by not calling such a witness. The case was reversed and remanded for further proceedings.

Dissents or concurrances

Justice Stewart joined but emphasized the ruling is narrow and does not create a blanket right to use juvenile records for general impeachment; Justice White (joined by Rehnquist) dissented, urging deference to trial-court discretion and state appellate review.