Blades v. United States
2011 D.C. App. LEXIS 375
| D.C. | 2011Background
- Appellant Blades was convicted on a one-witness case where James Bell testified Bell observed the stabbing of Charles Smith and identified Blades as the assailant.
- On direct examination Bell stated he was on good terms with Blades, had no reason to fabricate, and that Blades was like family to him.
- During cross-examination, defense sought to show Bell’s bias due to Bell’s stepson being shot years earlier, asserting Bell’s bias against Blades; the government objected to relevance.
- The court precluded any cross-examination about Bell’s possible hostility, deeming the bias theory far-fetched and speculative.
- Defense proffered several factual details linking Bell’s bias to the shooting incident near Gainesville Street and Bell’s belief Blades knew the shooter.
- The government’s case depended entirely on Bell’s credibility; no physical evidence connected Blades to the stabbing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court impermissibly barred bias cross-examination | Blades | United States | Yes; cross-examination on bias was improperly precluded |
| Whether the proffer established a proper foundation for bias questioning | Blades | United States | Foundation established; court erred in barring inquiry |
| Whether the error was harmless beyond a reasonable doubt | Blades | United States | No; error not harmless given sole witness and impact on credibility |
Key Cases Cited
- Melendez v. United States, 10 A.3d 147 (D.C.2010) (Confrontation Clause and bias cross-examination importance)
- Davis v. Alaska, 415 U.S. 308 (S. Ct. 1974) (Right to confront and cross-examine adverse witnesses)
- Van Arsdall v. United States, 475 U.S. 673 (U.S. 1986) (Harmless-error framework and factors for evaluating Confrontation Clause errors)
- Cunningham v. United States, 974 A.2d 240 (D.C.2009) (Foundation for bias cross-examination; latitude required)
- Best v. United States, 328 A.2d 378 (D.C.1974) (Sufficient foundation for bias inquiry; early rules on cross-examination)
- Howard v. United States, 978 A.2d 1202 (D.C.2009) (Fairly lenient foundation standard for bias cross-examination)
- Melvin v. United States, 952 A.2d 942 (D.C.2008) (Confrontation Clause standard; significant cross-examination rights)
- New York Life Ins. Co. v. Taylor, 147 F.2d 297 (D.C. Cir. 1944) (Impeachment and bias timing considerations in cross-examination)