EVIDENCE - IMPEACHMENT OF A
WITNESS BY FORMER CONVICTION
Evidence has been presented that [Name of Witness] has heretofore been convicted of (a criminal offense)/(criminal offenses). This evidence is called impeachment evidence, and it is offered to show that the witness's testimony is not believable or truthful. If you find that (this conviction)/(these convictions) occurred, you may consider this impeachment evidence in determining what weight and credit to give the credibility of that witness. You may not consider this impeachment evidence as proof of innocence or guilt of the defendant. You may consider this impeachment evidence only to the extent that you determine it affects the believability of the witness, if at all.
Notes on Use
The trial court should be especially careful when giving more than one limiting instruction to avoid inconsistencies between them. See Lewis v. State, 1998 OK CR 24 ¶ 22, 970 P.2d 1158, 1168 (limiting instructions on other crimes evidence and the basis of opinion testimony were confusing and contradictory when given together because the only evidence of other crimes came in as the basis of opinion testimony).