In this larceny trial, the trial court did err by allowing the State to cross-examine the defendant on his previous convictions for uttering a forged instrument, forgery, and obtaining property by false pretenses, all of which occurred more than 10 years ago. The court noted that it has held that under Rule 609 trial court must make findings as to the specific facts and circumstances demonstrating that the probative value of an older conviction outweighs its prejudicial effect and that a conclusory finding that the evidence would attack the defendant's credibility without prejudicial effect does not satisfy this requirement. It continued, however, stating that a trial court’s failure to follow this requirement “does not [necessarily constitute] reversible error.” (quotation omitted). It explained: “Where there is no material conflict in the evidence, findings and conclusions are not necessary.” (quotation omitted). Here, other than making a general objection, the defendant offered no evidence and made no attempt to rebut the State’s argument for admitting the prior convictions. Furthermore, a trial court’s failure to make the necessary findings is not error when the record demonstrates the probative value of prior conviction evidence to be obvious, and that principle applied in the case at hand. The court held: “although the trial court’s findings were conclusory and would normally be inadequate under Rule 609(b), the record contains facts and circumstances showing the probative value of the evidence.” Among other things, it noted that the defendant’s credibility was central to the case and that all of the prior crimes involved dishonesty. 

The trial court erred by allowing the State to impeach a defense witness with a prior conviction that occurred outside of the ten-year “look-back” for Rule 609 when the trial court made no findings as to admissibility. However, no prejudice resulted.