Can a witness be impeached for misconduct in a criminal case?

Wheeler recognized the danger of burdening trials with collateral issues of witness misconduct. (People v. Wheeler, supra, 4 Cal.4th at p. 290, 14 Cal.Rptr.2d 418, 841 P.2d 938.) It stated: "Of course, the admissibility of any past misconduct for impeachment is limited at the outset by the relevance requirement of moral turpitude. Beyond this, the latitude Evidence Code section 352 allows for exclusion of impeachment evidence in individual cases is broad. The statute empowers courts to prevent criminal trials from degenerating into nitpicking wars of attrition over collateral credibility issues. By expressly preserving this authority, California Constitution, article I, section 28(d) makes clear the voters' determination to prevent such consequences.

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