Melendez v. United States
10 A.3d 147
| D.C. | 2010Background
- Melendez was convicted at trial of second degree murder while armed for beating Benitez with a baseball bat, plus assault with a dangerous weapon and possession of a prohibited weapon.
- Defense argued misidentification; William Luna, not Melendez, committed the murder, and Melendez called Luna as an adverse witness in defense.
- Luna testified, then contradicted Melendez's account on cross-examination, including Luna's admission of a New York sentence arising from statements to a key witness.
- Melendez sought to show Luna's bias in favor of the government due to a New York stay-away order, aiming to prolifically cross-examine about that order.
- Trial court refused to allow examination about the stay-away order, ruling the line of questioning collateral and lacking proper foundation.
- Appellate court held that there was no error because defense failed to lay an adequate factual foundation linking Luna’s alleged conduct to bias against Melendez.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court violated the Sixth Amendment by limiting bias cross-examination. | Melendez argues Luna’s potential bias toward the government could affect reliability. | United States contends the proposed inquiry was collateral and lacked foundation. | No reversible error; trial court properly limited without adequate foundation. |
Key Cases Cited
- McClary v. United States, 3 A.3d 346 (D.C. 2010) (complete denial of cross-examination for bias violates confrontation rights)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (bias cross-examination requires probative relevance)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (defendant’s confrontation rights permit bias inquiry)
- Ray v. United States, 620 A.2d 860 (D.C. 1993) (foundational proffer required for bias questioning)
- Scull v. United States, 564 A.2d 1161 (D.C. 1989) (proper foundation necessary for bias cross-examination)
- Brown v. United States, 952 A.2d 942 (D.C. 2008) (proffer requirements for bias inquiry)
- Blunt v. United States, 863 A.2d 828 (D.C. 2004) (motive to curry favor as a basis for bias proof)
- Randolph v. United States, 882 A.2d 210 (D.C. 2005) (recording bias issues requires opportunity to develop record)
- McCraney v. United States, 983 A.2d 1041 (D.C. 2009) (lack of factual basis undermines bias inquiry)
- Jones v. United States, 516 A.2d 513 (D.C. 1986) (proffer must explain how witness is biased)