State v. Prange, 268 P.3d 749

Defendant sought to impeach the victim's credibility with stepdaughter testimony about the victim's wife's hostility and a prior false pellet-gun accusation.
The trial court excluded the stepdaughter testimony as impermissible 404(3) evidence and irrelevant.
Proffered testimony described a prior dispute where the victim's wife called the stepdaughter a slur and an accusation about a pellet gun was made; stepdaughter testified of ongoing hostility between the parties.
Defendant argued the evidence showed victim bias and motive to fabricate, linking the false pellet-gun report to the charged incident.
The jury convicted defendant of menacing and disorderly conduct; defense appealed the evidentiary ruling.
On appeal, court held the evidence was relevant to bias and that exclusion was error requiring reversal and remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the stepdaughter evidence admissible under OEC 404(3) to show victim bias?	Prange: evidence shows bias against defendant and motive to lie.	State: evidence is inadmissible as unrelated to defendant under 404(3).	Evidence admissible; tends to show bias and is relevant.
Was the trial court's exclusion proper under OEC 403 balancing?	Prange: exclusion was improper because bias evidence is highly probative and not unfairly prejudicial.	State: trial court could exclude to prevent prejudice/undue confusion.	Court found exclusion improper; 403 balancing did not justify exclusion under circumstances.
Was the error harmless or reversible?	Prange: bias testimony was necessary for credibility; its exclusion harmed the defense.	State: not harmless beyond reasonable doubt; other evidence sufficed.	Error not harmless; reversal and remand required.

State v. Titus, 328 Or. 475 (1999) (relevance standard for evidence)
State v. Haugen, 349 Or. 174 (2010) (bias admissibility—mere tendency suffices)
State v. Hubbard, 297 Or. 789 (1984) (bias evidence admissible unless undue speculation)
State v. Knobel, 97 Or. App. 559 (1989) (cross-examination and bias related to relationships)
State v. Phillips, 245 Or. App. 38 (2011) (limits on inferences to support bias theory)
State v. Hale, 335 Or. 612 (2003) (404(3) does not apply to non-crimes evidence of character)
State v. Fish, 239 Or. App. 1 (2010) (bias and credibility assessment context)
State v. Harberts, 198 Or. App. 546 (2005) (limits on inferred bias from sequence of inferences)
Outdoor Media Dimensions Inc. v. State of Oregon, 331 Or. 634 (2001) (right-for-the-wrong-reason approach to evidentiary rulings)
State v. Moore/Coen, 349 Or. 371 (2010) (404(3) applicability to non-defendant subjects)