Melendez v. United States

Summary

The District of Columbia Court of Appeals affirmed Hernan Melendez's convictions for second-degree murder while armed, assault with a dangerous weapon, and possession of a prohibited weapon. The court held that the trial court properly excluded proposed questioning of prosecution witness William Luna concerning alleged bias because defense counsel failed to make an adequate factual proffer establishing that Luna had violated a New York stay-away order or had reason to curry favor with the government.

Holdings

1. Before a defendant may pursue a line of questioning suggesting that a witness is biased, counsel must lay a proper foundation by proffering facts supporting a genuine belief or well-reasoned suspicion that the witness is biased in the asserted manner.
2. The trial court did not err in precluding the proposed examination because defense counsel failed to provide an adequate factual proffer that Luna had violated the New York stay-away order or that the alleged violation created a bias in favor of the government.

Questions Presented

1. Whether the trial court violated Melendez's Sixth Amendment right to confront witnesses by precluding cross-examination of William Luna concerning an alleged violation of a New York stay-away order and the resulting potential bias in favor of the government.
2. Whether defense counsel laid a sufficient factual foundation to establish that the proposed inquiry was relevant and probative of Luna's alleged bias.

Disposition

affirmed