182074P.pdf   12/26/2018  United States  v.  Kevin Naholi
   U.S. Court of Appeals Case No:  18-2074
   U.S. District Court for the Northern District of Iowa - Cedar Rapids   
   [PUBLISHED] [Erickson, Author, with Benton and Beam, Circuit Judges] 
   Criminal case - Criminal law. Defendant should have been allowed to 
   introduce the government witness's conversation with defendant's wife for 
   purposes of impeaching the wife, as the evidence was not hearsay and 
   should have been permitted as extrinsic evidence of a prior inconsistent 
   statement; however, the error was harmless in light of the evidence of 
   defendant's guilt and the fact that defendant was allowed to introduce 
   other evidence of his wife's credibility; any further evidence undermining 
   her credibility would not have had a significant impact on the outcome of 
   the case; the prosecutor's comments during closing argument did not 
   impermissibly shift the burden of proof.