See also: CONFRONTATION–Limiting Cross-Examination
GEOGRAPHY.; INFORMANT’S PRIVILEGE

1.  Generally

A witness’ address is generally considered relevant as background.{footnote}United States v. Opager, 589 F.2d 799 (5th Cir. 1979).{/footnote}   A witness’ address may be relevant to lay a foundation for the testimony of character witnesses.{footnote}United States v. Conder, 423 F.2d 904 (6th Cir. 1970).{/footnote} 

2.  Prosecution Witnesses

The defense is generally entitled under the Confrontation Clause to elicit from a prosecution witness their current place of residence, without any necessity of explaining the purpose of the question.{footnote}Smith v. Illinois, 390 U.S. 129 (1968) (reversing conviction where undercover agent permitted to testify without giving name or address); Alford v. U.S., 282 U.S. 687 (1931) (reversing conviction where government witness’s address, apparently a prison, withheld).
But see McGrath v. Vinzant, 528 F.2d 681, 684 (1st Cir.), cert. dism’d, 426 U.S. 902 (1976) (in upholding non-disclosure of the testifying rape victim’s address, court noted that defense did not identify any likely relevance of the address).
But see State v. Capone, 347 A.2d 615, 622 (R.I. 1975) (in upholding conviction, noting that defendant failed to provide any reason for asking for address and failed to demonstrate any harm from non-disclosure).
CHECK U.S. v. Honneus, 508 F.2d 566, 572 (1st Cir. 1974), cert. denied, 421 U.S. 948 (1975).{/footnote}  In Smith v. Illinois, the United States Supreme Court wrote:

When the credibility of a witness is in issue, the very starting point in ‘exposing falsehood and bringing out the truth’ through cross-examination must necessarily be to ask the witness who he is and where he lives.  The witness’ name and address open countless avenues of in-court examination and out-of-court investigation. To forbid this most rudimeontary inquiry at the threshold is effectively to emasculate the right of cross-examination itself.{footnote}Smith v. Illinois, 390 U.S. at 131.{/footnote}

Similarly, the Court wrote in Alford v. United States:

The question ‘Where do you live?’ was not only an appropriate preliminary to the cross-examination of the witness but on its face, without any such declaration of purpose as was made by counsel here, was an essential step in identifying the witness with his environment, to which cross-examination may always be directed. . . .{footnote}282 U.S. at ___.{/footnote}

This rule is not absolute, however.{footnote}McGrath v. Vinzant, 528 F.2d 681, 684 (1st Cir.), cert. dism’d, 426 U.S. 902 (1976); U.S. v. Lonetree, 35 M.J. 396 (C.M.A. 1991).
CHECK Clark v. Ricketts, 886 F.2d 1152 (9th Cir. 1989).{/footnote}  The trial court retains discretionary authority to preclude cross-examination which merelty tends to “harass, annoy or humiliate” a witness.{footnote}Alford v. U.S., 282 U.S. at 694; U.S. v. Alston, 460 F.2d 48 (5th Cir.), cert. denied, 409 U.S. 871 (1972) (upholding non-disclosure of witness’s home address).{/footnote}  In addition, courts have upheld non-disclosure of undercover law enforcement officers’ home addresses.{footnote}U.S. v. Alston, 460 F.2d 48, 51 (5th Cir.), cert. denied, 409 U.S. 871 (1972) (drug case).
People v. Pleasant, 244 N.W.2d 464 (Mich. App. 1976); Brown v. State, 580 P.2d 947, 950-51 (Nev. 1978).{/footnote}  The address of a prosecution witness may be withheld where there is a showing of a threat to the witness’ safety.{footnote}U.S. v. Perisco, 425 F.2d 1375, 1383 (2d Cir.), cert. denied, 400 U.S. 869 (1970); U.S. v. Rich, 262 F.2d 415 (2d Cir. 1959); U.S. v. Avalos, 541 F.2d 1100, 1117 (5th Cir. 1976) (witnesses in protection program); U.S. v. Crockett, 506 F.2d 759, 762 (5th Cir.), cert. denied, 423 U.S. 824 (1975) (witnesses in protection program); U.S. v. Alston, 460 F.2d 48, 51 (5th Cir.), cert. denied, 409 U.S. 871 (1972) (drug case); United States v. Fife, 573 F.2d 369 (6th Cir. 1976); United States v. Palermo, 410 F.2d 468 (7th Cir. 1969); U.S. v. Saletko, 452 F.2d 193 (7th Cir.), cert. denied, 405 U.S. 1040 (1971); Kirschbaum v. U.S., 407 F.2d 562 (8th Cir. 1969); U.S. v. Rangel, 534 F.2d 147 (9th Cir. 19__) (witness had been threatened, forcing him to relocate).
State v. District Court, 933 P.2d 22 (Colo. 1997) (witness in protection program); State v. Capone, 347 A.2d 615, 622 (R.I. 1975) (witness in protective custody).
See also Smith v. Illinois, 390 U.S. at 133-34 (White & Marshall, J.J., concurring).
Check Clark v. Ricketts, 886 F.2d 1152 (9th Cir. 1989); U.S. v. Harris, 501 F.2d 1, 9 (9th Cir. 1974).{/footnote}  While a proper record must ordinarily be made of the existence of a threat to the witness’s safety,{footnote}U.S. v. Dickens, 417 F.2d 958, 962 (8th Cir. 1969) (reversing where accomplice’s address withheld).{/footnote} even where no explicit showing or finding of an actual threat has been made, the court may infer a threat which is inherent in the context of the trial.{footnote}McGrath v. Vinzant, 528 F.2d 681, 684 (1st Cir.), cert. dism’d, 426 U.S. 902 (1976) (rape victim’s address); U.S. v. Daddano, 432 F.2d 1119, 1128 (7th Cir. 1970), pet. for cert. dism’d, 401 U.S. 967, cert. den., 402 U.S. 905 (1971) (involving attempts to silence witnesses).
Contra Pigg v. State, 603 N.E.2d 154, 157 (Ind. 1992) (where there has been no in camera hearing on reasons for non-disclosure of address, prejudice is presumed); Morrison v. State, 609 N.E.2d 1155, 1158 (Ind. App. 1993) (same; reversing drug possession conivtions where informant’s address withheld).{/footnote}  Withholding the address is particularly appropriate where other evidence is available as to a witness’ general environment.{footnote}McGrath v. Vinzant, 528 F.2d 681, 685 (1st Cir.), cert. dism’d, 426 U.S. 902 (1976); United States v. Mesa, 660 F.2d 1070 (5th Cir. 1981); U.S. v. Alston, 460 F.2d 48 (5th Cir.), cert. denied, 409 U.S. 871 (1972); United States v. Fife, 573 F.2d 369 (6th Cir. 1976).
State v. District Court, 933 P.2d 22 (Colo. 1997) (witness’s former address and phone number disclosed); Brown v. State, 580 P.2d 947, 950-51 (Nev. 1978); State v. Capone, 347 A.2d 615, 622 (R.I. 1975) (witness in protective custody)
But see U.S. v. Dickens, 417 F.2d 958, 962 (8th Cir. 1969) (in reversing where accomplice’s address withheld, stating that other background information known to defendant negates force of argument for withholding address).{/footnote}