Delaware v. Van Arsdall
Annotate this Case
475 U.S. 673 (1986)
U.S. Supreme Court
Delaware v. Van Arsdall, 475 U.S. 673 (1986)
Delaware v. Van Arsdall
Argued January 22, 1986
Decided April 7, 1986
475 U.S. 673
During respondent's murder trial, the Delaware trial court refused to allow defense counsel to cross-examine a prosecution witness about an agreement that he had made to speak with the prosecutor about the murder in question in exchange for the dismissal of an unrelated criminal charge against him. Respondent was convicted. The Delaware Supreme Court reversed on the ground that the trial court, by improperly restricting defense counsel's cross-examination designed to show bias on the prosecution witness' part, violated respondent's rights under the Confrontation Clause of the Sixth Amendment, and refused to consider whether such ruling was harmless beyond a reasonable doubt.
Held: While the trial court's denial of respondent's opportunity to impeach the prosecution witness for bias violated respondent's rights under the Confrontation Clause, such ruling is subject to harmless error analysis under Chapman v. California, 386 U. S. 18. 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 number of factors, including the importance of the witness' testimony, whether the testimony was cumulative, the presence or absence of corroborating or contradictory testimony on material points, the extent of cross-examination otherwise permitted, and the overall strength of the prosecution's case. Pp. 475 U. S. 681-684.
486 A.2d 1, vacated and remanded.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, BLACKMUN, POWELL, and O'CONNOR, JJ., joined. WHITE, J., filed an opinion concurring in the judgment, post, p. 475 U. S. 684. MARSHALL, J., post, p. 475 U. S. 686, and STEVENS, J., post, p. 475 U. S. 689, filed dissenting opinions.
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