California, United States of America
The following excerpt is from People v. Guzman, B225358 (Cal. App. 2011):
Following briefing, we asked the parties to address the applicability of People v. Wheeler (1992) 4 Cal.4th 284 (Wheeler), the seminal case on the admissibility of misdemeanor convictions for impeachment purposes. In a supplemental brief, defendant argued, "the admission of [defendant's] misdemeanor conviction violated the principles in Wheeler because a misdemeanor conviction is inadmissible hearsay." The Attorney General urged that because trial counsel objected on the grounds that the conviction was remote and could not be used as propensity evidence, defendant's belated hearsay claim is forfeited. We agree with the Attorney General.
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