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The constitutional right to present a defense does not include the right to introduce any and all evidence claimed to support it. When defense evidence is excluded, such exclusion may give rise to a claim of denial of the right to present a defense. Although exclusionary rules of evidence should not be applied mechanistically to deprive a defendant of his rights, the constitution does not require that a defendant be permitted to present every piece of evidence he wishes. A trial court retains the power to rule on the admissibility of evidence pursuant to traditional evidentiary standards. The question of the admissibility of the proffered evidence is one of evidentiary, but not constitutional, dimension.
Defendant Abdullah Shabazz was on a pay phone when the victim approached him and slapped him in the face. A fight ensued during which defendant stabbed the victim. The victim died after undergoing surgery. During the trial, the judge denied defendant's motion to disqualify, and excluded evidence that medical negligence caused the victim's death, opinion evidence regarding the victim's violent character, and evidence of defendant's spontaneous utterance after the incident. Defendant challenged the impartiality of the trial judge and the validity of the superior court's evidentiary rulings on appeal.
Could the defendant’s conviction be sustained, notwithstanding the issues raised by the defendant?
The court affirmed the defendant’s murder conviction, holding that there was no evidence from which the jury could have inferred that the hospital's gross negligence was the sole cause of the victim's death, that the character evidence was cumulative to an issue that was not in dispute, and that the superior court's exclusion of defendant's statement was not an abuse of discretion. The court further found that defendant's claim that a reasonable person might question the impartiality of the trial judge with respect to an African-American because the judge's father had been killed by an African-American was nothing but speculation.