Martinez v. State
416 Md. 418
| Md. | 2010Background
- Martinez was convicted of involuntary manslaughter and attempted murder in Prince George's County Circuit Court.
- State's key witness Mejicanos testified under a body attachment writ after missing earlier trial dates.
- Defense sought to impeach Mejicanos by showing potential bias stemming from nolle prosequied charges and custody status.
- Court denied cross-examination on those bias-related topics under Rule 5-403.
- Court of Special Appeals upheld the ruling; Maryland: Calloway v. State later required reversal.
- Maryland Court of Appeals granted certiorari to decide if the trial court erred by limiting bias impeachment of a key witness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court violated the Confrontation Clause by limiting bias cross-examination. | Martinez; Mejicanos's bias evidence warranted inquiry. | State; Rule 5-403 properly limited potentially prejudicial inquiry. | No; the limitation violated confrontation, requiring a new trial. |
Key Cases Cited
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (cross-examination on bias permissible to show motive to testify falsely)
- Van Arsdall v. State, 475 U.S. 673 (U.S. 1986) (limits on cross-examination; balance of probative value and prejudice)
- Smallwood v. State, 320 Md. 300 (1990) (test for bias evidence in cross-examination; prevent confusion)
- Calloway v. State, 414 Md. 616 (Md. 2010) (reversible error when trial court barred bias inquiry; adopts bias framework)
- Brown v. State, 74 Md.App. 414 (Md. 1988) (threshold level of inquiry before limiting cross-examination)
- Leeks v. State, 110 Md.App. 543 (Md. 1996) (bias evidence may be established by circumstantial evidence; jurors observe demeanor)