The majority also appears to overrule two prior pronouncements of this Court establishing the parameters for impeachment of nondefendant witnesses. People v Atkins #2, 406 Mich. 958 (1979); People v Tait, 136 Mich. App. 475; 356 N.W.2d 33 (1984). The question of the proper rule for nondefendant witnesses has neither been briefed nor argued here.
Davis is distinguishable from the case at hand on its facts and because it dealt with bias rather than credibility of a witness. State cites the case of People v. Tait, 136 Mich. App. 475, 356 N.W.2d 33 (1984), which is on point. Michigan's statute, like SDCL 19-14-12, fails to limit the balancing of the probative value against the prejudicial effect only to the defendant.
The crime of escape is generally recognized as not directly involving dishonesty or deception. See, e.g., Eng v. Scully, 146 F.R.D. 74, 79 (S.D.N.Y. 1993); People v. Holt, 208 Cal.Rptr. 547, 557, 37 Cal.3d 436, 454-55, 690 P.2d 1207, 1217 (1984); People v. Tait, 136 Mich. App. 475, 356 N.W.2d 33, 36 (1984). Furthermore, the State did not attempt to admit Eugene's felony escape conviction under Rule 609(a)(ii), N.D.R.Ev., as a crime involving dishonesty or false statement.