State v. Naudain, 487 P.3d 32

In 1998, Damon Naudain (Black) and a white accomplice, Michael Jump, robbed the home of Jerry Hartman; Hartman was shot and killed; Julie Beachell (fiancée, cohabitant, and mother of Hartman’s child) was a witness.
A police report reflected Beachell’s statements that Hartman refused to associate with or allow Black people in his home and that a former housemate (Melissa Sparks) was asked to move out for bringing Black acquaintances to the residence.
At retrial, Naudain sought to cross-examine Beachell about Hartman’s racial views (and the house rule) to show that Beachell tolerated or shared those views and thus was racially biased in describing the perpetrators.
The trial court granted the state’s motion in limine and precluded that line of questioning, ruling the victim’s views were irrelevant and, alternatively, inadmissible under OEC 403.
Naudain was convicted; the Court of Appeals reversed the evidentiary ruling; the Oregon Supreme Court granted review and affirmed the Court of Appeals, reversing the circuit court and remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence of the victim’s racial views was relevant to show the witness’s racial bias	Mere association with a biased person does not provide a logical nexus; no evidence that Beachell personally shared Hartman’s views	Intimate relationship, shared household, a house rule excluding Black people, and Beachell’s own references to the rule permit a reasonable inference she tolerated/shared those views	Relevant: reasonable inference exists given engagement, cohabitation, child, and house rule (trial court erred)
Whether exclusion under OEC 403 was proper	Any probative value is low and substantially outweighed by unfair prejudice (smearing the victim; inflammatory)	Probative value significant to impeach the prosecution’s key eyewitness; risk of unfair prejudice low and exclusion impairs effective cross-examination	Trial court abused discretion: probative value significant and danger of unfair prejudice low; exclusion not justified

State v. Hubbard, 297 Or 789 (1984) (bias or interest of an adverse witness is admissible impeachment)
State v. Titus, 328 Or 475 (1999) (relevance has a very low threshold)
State v. Turnidge, 359 Or 364 (2016) (relevance requires a rational/logical connection; inferences may suffice)
State v. Mayfield, 302 Or 631 (1987) (OEC 403 balancing steps and assessing probative value and need)
State v. Lyons, 324 Or 256 (1996) (defining unfair prejudice under OEC 403)
Davis v. Alaska, 415 U.S. 308 (1974) (denial of effective cross-examination can be constitutional error)
State v. Knight, 343 Or 469 (2007) (OEC 403 exclusion is an exercise of trial-court discretion)
State v. Williams, 313 Or 19 (1992) (standard of review for OEC 403 rulings)
State v. Skillicorn, 367 Or 464 (2021) (character or derogatory evidence can distract the factfinder and present unfair prejudice)