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(holding that the trial court erred in failing to allow the defendant to cross-examine the victim as to her first offender status to show possible bias).” Clark v. State, 335 Ga.App. 747, 782 S.E.2d 828 (February 22, 2016). Physical precedent only. Armed robbery conviction affirmed; trial court properly excluded “evidence of the victim’s prior first offender guilty plea to an offense of possession of marijuana with intent to distribute,” offered by defendant “to contradict facts to which [victim] testified. … But even assuming for the sake of argument that a first offender plea could be used against a witness in a criminal case to disprove or contradict his testimony, Clark has made no showing that evidence of the victim’s first offender plea in a prior unrelated case would have disproved his testimony in this case that he was robbed during a purported drug transaction.” Rivers v. State, 296 Ga. 396, 768 S.E.2d 486 (January 20, 2015). Felony murder and related convictions affirmed. Trial court properly prohibited defense from impeaching State’s witness with prior first offender plea, not for general impeachment, but to disprove his testimony about facts underlying the plea. The subject matter of the plea, however, was irrelevant to the case on trial. Witness Sullivan “testified that he was not the aggressor in his altercation with [co-defendant] Perrymond. Appellant sought on cross-examination to impeach Sullivan by offering evidence of Sullivan's 1995 first offender plea to a charge of aggravated assault. … [E]ven assuming, as appellant argues, that a first offender plea may be used against a witness in a criminal case to disprove or contradict facts to which the witness testifies, see Matthews [ v. State, 268 Ga. 798, 802, n.2 (493 S.E.2d 136) (1997)] , inasmuch as Sullivan was not the victim of the charged crimes and Perrymond was not the defendant, evidence of Sullivan's prior act of violence against a third party was not admissible under Chandler v. State, 261 Ga. 402, 407(3)(b) (405 S.E.2d 669) (1991), and, quite simply, was not pertinent to the critical fact in question in appellant's justification defense, whether appellant's action in striking [victim] Tanks were justified.” Carruth v. State, 290 Ga. 342, 721 S.E.2d 80 (January 9, 2012). Malice murder and related convictions affirmed; defendant’s prior first offender plea to burglary was properly admitted to impeach his testimony that he didn’t commit the burglary. Sanders v. State, 290 Ga. 445, 721 S.E.2d 834 (January 9, 2012). Malice murder and related convictions affirmed; trial court properly prohibited cross-examination of State’s witness on his first offender burglary probation. “Sanders did not make a proffer explaining why [witness] Baker would want to curry favor with the prosecutor or the benefit he hoped to gain from his testimony. Instead, Sanders argued that the witness was biased and had a motive to testify favorably based on two unsupported assumptions: (1) Baker's second plea in Clayton County meant his first offender status in Fulton County would be revoked and (2) the Fulton County District Attorney's Office would be responsible for seeking the revocation. Sanders presented no evidence that the State intended to seek revocation of Baker's first offender status in either Fulton or Clayton County, Baker was aware that his probation in Fulton County could be revoked based on his Clayton County plea, or the district attorney's office intended to make any recommendation in connection with a possible revocation. Under OCGA § 42–8–38(a), the probation supervisor has the responsibility to prosecute any revocation, not the district attorney. Sanders needed to present facts in addition to the existence of two first offender pleas to support his efforts to impeach the witness for bias. See Turtle v. State, 271 Ga. 440, 444(4) (520 S.E.2d 211) (2003) (permitting cross-examination of witness concerning pending criminal charges and a pending probation revocation to show bias ); Scott v. State, 242 Ga.App. 850, 852 (527 S.E.2d 210) (1999) (allowing cross-examination of co-defendant about petition seeking revocation of her first offender probation when there was an outstanding bench warrant). Without some evidence showing the connection between Baker's first offender status and his desire to shade his testimony to curry favor with the State, the trial court did not abuse its discretion in prohibiting the cross-examination about the Fulton County plea.” Accord, Armour v. State , 290 Ga. 553, 722 S.E.2d 751 (February 27, 2012) (quoting bolded language above); Redding v. State , 296 Ga. 471, 769 S.E.2d 67 (February 2, 2015). Manley v. State, 287 Ga. 338, 698 S.E.2d 301 (March 1, 2010). At defendants’ murder trial, trial court erred, but harmless, by refusing to allow defendants to impeach informant with pending first offender sentence. “The record shows that, at the time of [his statement to police], the informant had certain charges pending against him. In the interim between making this statement and the co-defendants' trial, the informant pled guilty to a first-offender violation and was placed on probation. During trial, the co-defendants wished to question the informant about this offense to show the potential for bias at the time that he gave his initial statement. The trial court, however, prevented such questioning on the basis that first offender records are inadmissible to impeach a witness on general credibility grounds. See Marks v. State, 280 Ga. 70(3) (623 S.E.2d 504) (2005). While that is generally true, the co-defendants did not wish to impeach the
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