United States v. Cedeño, et al, No. 09-1857 (2d Cir. 2011)
Annotate this CaseDefendant was convicted of kidnapping, robbery, and related crimes and was sentenced principally to 319 months imprisonment. At issue was whether the district court properly limited cross-examination of a government witness at trial by barring his use of a state court's finding that the witness had given false testimony in a prior judicial proceeding. The court held that the district court's evidentiary ruling was erroneous but found that the error was harmless where the witness testified primarily about the arrest of two co-conspirators and the discovery of incriminating evidence during their arrest and mentioned in passing the police's non-custodial questioning of defendant and where other officers fully corroborated the testimony.
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