Cynthia Sanchez v. District of Columbia

Summary

The District of Columbia Court of Appeals held that the trial court erroneously exercised its discretion by excluding the defense expert from hearing the cross-examination of the government’s fact and expert witness. The court concluded that the exclusion prejudiced the defendant’s ability to evaluate the administration of field sobriety tests and to assist counsel during cross-examination. The court reversed Sanchez’s conviction for driving under the influence.

Holdings

1. The trial court erroneously exercised its discretion by excluding the defense expert from the courtroom during the government's expert's cross-examination without identifying a valid reason and without allowing the defense to show why the expert's presence was essential to the presentation of the defense.
2. The erroneous exclusion of Palacios prejudiced Sanchez and constituted an abuse of discretion requiring reversal.

Questions Presented

1. Whether the trial court abused its discretion by sua sponte excluding the defense expert from hearing the government's expert's cross-examination and demonstration of the sobriety tests.
2. Whether the erroneous exclusion of the defense expert was prejudicial and required reversal.
3. Whether the trial judge's alleged advocacy and limitation of cross-examination independently violated Sanchez's due process or Confrontation Clause rights.

Disposition

reversed