Dawkins v. United States, 41 A.3d 1265

Dawkins was indicted on three DC offenses related to possession of a loaded firearm.
He pled guilty to all counts but reserved the right to appeal the suppression ruling.
The suppression hearing centered on whether Dawkins consented to a pat-down search.
Officer Solgat testified Dawkins mumbled consent; Dawkins claimed he merely cooperated as asked.
During cross-examination, Dawkins attempted to probe a pending civil suit against Solgat for false arrest.
The trial court refused to hear any proffer on the relevance of the civil suit and limited cross-examination elsewhere; the court ultimately denied the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Dawkins's error preservation valid?	Dawkins preserved by proffering relevance of the civil suit when blocked.	No proffer was requested or entertained, so no preservation.	Dawkins preserved the issue.
Did the trial court abuse its discretion by excluding bias cross-examination without a proffer?	Civil-suit bias bears on Solgat's credibility; proffer required.	Questioning outside scope should be barred; no proffer needed.	Yes, abuse of discretion.
Was the error harmless or did it affect the suppression ruling?	Solgat's credibility was core; bias evidence would likely change outcome.	Without proffer, error could be harmless.	Not harmless; likely affected judgment.

Martinez v. United States, 982 A.2d 789 (D.C. 2009) (allows broader bias cross-examination in suppression context)
Foreman v. United States, 792 A.2d 1043 (D.C. 2002) (bias cross-examination is relevant to credibility)
Blunt v. United States, 863 A.2d 828 (D.C. 2004) (prohibiting all inquiry into possible bias error)
Delaware v. Van Arsdall, 475 U.S. 673 (U.S. Supreme Court, 1986) (limits on exclusion of bias evidence in trials)
McBride v. United States, 441 A.2d 644 (D.C. 1982) (preservation when trial court signals unwillingness to hear proffer)