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 'A witness may not be impeached by contradiction as to collateral or irrelevant matters elicited on cross-examination,' United States v. Lambert, 463 F.2d 552, 557 (7th Cir. 1972). Since the test for whether a matter is collateral is 'whether the party seeking to introduce it for purposes of contradiction would be entitled to prove it as part of his case,' id.. 


The collateral evidence rule was developed in conjunction with a particular type of impeachment -- impeachment by contradiction. Impeachment by contradiction simply involves presenting evidence that part or all of a witness' testimony is incorrect. Thus, if an eyewitness to an auto accident testifies that the car that caused the accident was red, impeachment by contradiction relies on evidence that the car actually was yellow. The inference to be drawn is not that the witness was lying, but that the witness made a mistake of fact, and so perhaps her testimony may contain other errors and should be discounted accordingly.


Of course, a particular misstatement may or may not be probative of the witness' general accuracy, depending on the circumstances, and thus may or may not be worth the time it takes to ...

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