United States v. Quincy Marquice Taylor, 127 F.4th 1008

Quincy Taylor was convicted by a jury of drug and firearm offenses after an accident in which a witness, William Howell, connected him to a bag containing drugs and a gun.
Howell, the only eyewitness tying Taylor to the contraband, had his own pending and prior criminal charges at the time of trial.
Taylor sought to cross-examine Howell on these charges and any promised leniency, arguing potential bias due to Howell’s cooperation with prosecutors.
The district court limited cross-examination, allowing only a question on whether Howell had a felony conviction, but barring inquiries into the nature of the conviction, pending charges, or potential benefits for testimony.
The jury convicted Taylor on all counts; his sentence was enhanced under the ACCA. Taylor appealed, citing Confrontation Clause and due process violations.

Issue	Taylor's Argument	Gov't Argument	Held
Limitation on Cross-Examination (Confrontation Clause)	Court’s limitation prevented inquiry into Howell’s bias/motive, violating Sixth Amendment rights.	Sought to exclude such inquiry to avoid undue prejudice and trial distraction.	Limiting cross-exam was a Confrontation Clause violation; not harmless error; reversal required.
ACCA Enhancement & Jury Factfinding	Jury should have decided if prior offenses were on separate occasions per Erlinger.	Not substantively addressed due to resolution on Confrontation Clause grounds.	Not decided; to be addressed on remand per new Supreme Court law.

Davis v. Alaska, 415 U.S. 308 (cross-examination for bias is core to Confrontation Clause)
Delaware v. Van Arsdall, 475 U.S. 673 (limiting cross-exam can violate the Confrontation Clause)
United States v. Callahan, 801 F.3d 606 (sufficient info on witness bias can cure cross-exam limits)
United States v. Fields, 763 F.3d 443 (cross-exam scope and bias)
Stevens v. Bordenkircher, 746 F.2d 342 (cannot limit cross-exam to mere fact of conviction)