Delaware v. Van Arsdall

475 U.S. 673, 106 S. Ct. 1431 (1986)

 

RULE:

Whether an error is harmless in a particular case depends upon a host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the overall strength of the prosecution's case. 

FACTS:

During the murder trial of the respondent, Robert Van Arsdall, the Delaware trial court refused to allow defense counsel to cross-examine a prosecution witness about an agreement that he had made with the prosecutor about the murder in question, in exchange for the dismissal of an unrelated criminal charge against him. Respondent was thereafter convicted. The Delaware Supreme Court reversed on the ground that the trial court violated respondent's rights under the Confrontation Clause of the Sixth Amendment by improperly restricting defense counsel's cross-examination designed to show bias on the prosecution witness' part. The Court refused to consider whether such ruling was harmless beyond a reasonable doubt.

ISSUE:

Should the state supreme court considered whether the trial court’s ruling was harmless in the context of the trial as a whole?

ANSWER:

Yes.

CONCLUSION:

The Court held that the constitutionally improper denial of a defendant's opportunity to impeach a witness for bias, like other Confrontation Clause errors, is subject to Chapman harmless-error analysis. Consequently, the Court asserted that the determination whether the Confrontation Clause error was harmless beyond a reasonable doubt was best left to the state supreme court in the first instance. The Court noted that the correct inquiry is whether, assuming that the damaging potential of the cross-examination were fully realized, a reviewing court might nonetheless say that the error was harmless beyond a reasonable doubt. Whether such an error is harmless in a particular case depends upon a host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted and the overall strength of the prosecution's case.

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