Scott Everett Shine v. State, 06-16-00088-CR

Scott Everett Shine was convicted in three consolidated indictments for engaging in organized criminal activity by delivering methamphetamine; his sentence (with enhancements) was life imprisonment.
At trial Shine cross-examined DPS Special Agent Danny Kelly about the arrest warrants Kelly prepared for Shine.
Shine sought to elicit that the arrest warrants charged only delivery of methamphetamine, not engaging in organized criminal activity.
The trial court sustained the State’s objection and limited that line of cross-examination as confusing and not shown relevant; Shine made an offer of proof reflecting Kelly would testify the warrants listed delivery, not organizational allegations, though Kelly said the investigation did allege organization.
Shine argued the limitation infringed his Sixth Amendment confrontation rights and that the warrant charge would show he was guilty only of the lesser offense; the court of appeals reviewed whether the limitation was an abuse of discretion or constitutional error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred in limiting cross-examination about the content of arrest warrants	Shine: Excluding testimony that warrants charged only delivery impaired his confrontation right and bore on guilt for organized criminal activity	State: The content of the warrants was not relevant to guilt for the charged offense and could confuse jury; prosecutor decides charges	Court: No abuse of discretion; limitation proper and not a constitutional deprivation

Hammer v. State, 296 S.W.3d 555 (Tex. Crim. App. 2009) (Confrontation Clause does not automatically override state evidentiary rules; trial judges have wide discretion)
Delaware v. Van Arsdall, 475 U.S. 673 (1986) (trial courts may impose reasonable limits on cross‑examination for several concerns)
Delaware v. Fensterer, 474 U.S. 15 (1985) (Confrontation Clause guarantees opportunity for effective cross‑examination, not limitless cross‑examination)
Davis v. Alaska, 415 U.S. 308 (1974) (bias impeachment through cross‑examination can be constitutionally protected)
Potier v. State, 68 S.W.3d 657 (Tex. Crim. App. 2002) (excluded impeachment evidence must go to the heart of the defense to trigger constitutional error)
Carroll v. State, 916 S.W.2d 494 (Tex. Crim. App. 1996) (trial court discretion to limit inappropriate cross‑examination)
Cameron v. State, 241 S.W.3d 15 (Tex. Crim. App. 2007) (admissibility reviewed for abuse of discretion)
Neal v. State, 150 S.W.3d 169 (Tex. Crim. App. 2004) (prosecutorial discretion to decide charges)
Bordenkircher v. Hayes, 434 U.S. 357 (1978) (prosecutor’s broad charging discretion)
Rock v. Arkansas, 483 U.S. 44 (1987) (denial to testify can implicate constitutional rights)
Chambers v. Mississippi, 410 U.S. 284 (1973) (exclusion of reliable exculpatory hearsay can violate due process)
Ferguson v. Georgia, 365 U.S. 570 (1961) (state evidentiary rules can implicate constitutional rights in extreme cases)