This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A single-car accident occurred, resulting in all four occupants being ejected from the vehicle, with one fatality. The State alleges that the Defendant was the driver and charged her with homicide by vehicle, two counts of great bodily harm by vehicle, driving without a license, and driving without proof of insurance. The Defendant claims that one of the State's witnesses was the actual driver and that both witnesses have motives to lie, potentially related to their criminal histories (paras 3-4).
Procedural History
- District Court: Granted Defendant's motion in limine to exclude two of the State's witnesses.
Parties' Submissions
- Appellant (State): Argued that the district court erred by not conducting the required analysis under State v. Harper and State v. Le Mier before excluding the witnesses as a sanction for a discovery violation (para 2).
- Appellee (Defendant): Argued that the State should provide the FBI's criminal histories of the witnesses, which are relevant to their credibility and potential motives to lie (para 3).
Legal Issues
- Whether the district court erred in excluding the State's witnesses without conducting the required analysis under State v. Harper and State v. Le Mier.
- Whether the State had an obligation to provide the FBI's criminal histories of the witnesses to the Defendant.
Disposition
- The Court of Appeals reversed the district court's decision and remanded the case for further proceedings (para 10).
Reasons
Per Duffy J. (Ives and Wray JJ. concurring):
The district court failed to conduct the necessary analysis under State v. Harper and State v. Le Mier before excluding the witnesses. The exclusion of witnesses is a severe sanction that requires consideration of the culpability of the party violating the court order, the prejudice suffered by the opposing party, and whether witness exclusion is the least severe sanction. The district court did not hold a hearing or provide an explanation of its reasoning under these factors, making the record inadequate for review. Therefore, the case was reversed and remanded for further development of the record (paras 8-9).