Summary
The Supreme Judicial Court of Massachusetts held that the trial judge abused his discretion by barring all inquiry into the complainant’s possible bias arising from pending criminal complaints that the defendant had sought and obtained against her. The court found the error prejudicial, reversed the judgment, set aside the verdict, and remanded the case for a new trial.
Topics
Practice areas
Questions Presented
- Whether the trial judge violated the defendant's right to confrontation by barring all cross-examination of the complainant concerning her possible bias arising from pending criminal complaints.
- Whether the exclusion of that bias evidence prejudiced the defendant and required a new trial despite the defense's ability to expose inconsistencies in the complainant's testimony.
Holdings
- A defendant has a right to reasonable cross-examination to show a witness's bias and prejudice, and a judge may not bar all inquiry into alleged bias when there is some basis, however remote, for the inquiry. The judge therefore erred by excluding all inquiry into the complainant's knowledge that Martin had previously applied for a criminal complaint against her and into the possible effect of the pending complaints on her motive.
- The error was prejudicial because the case turned on the credibility of conflicting witnesses, and exposing inconsistencies in the complainant's testimony did not substitute for evidence of her motive or bias. A new trial was required.
Key quotations
“It is a basic rule that reasonable cross-examination for the purpose of showing bias and prejudice is a matter of right.” (434 Mass. 1016)
“Rather, the evidence of bias is what provides an explanation for the inconsistencies, tending to show that they are indicative of actual fabrication and thus less worthy of credence.” (434 Mass. 1016)
“The judgment is reversed, the verdict set aside, and the case remanded for a new trial.” (434 Mass. 1016)
Factual background
Martin was convicted of assault and battery based largely on conflicting testimony concerning an alleged incident involving the complainant, with whom he had a close but brief relationship. Before trial, Martin had applied for and obtained two criminal complaints against the complainant, and the complainant had obtained pending complaints against Martin. The trial judge barred all inquiry into the complainant's possible bias arising from those complaints, although the defense was permitted to identify some inconsistencies in her testimony. The corroborating police witness was not a percipient witness and relied largely on what the complainant had told him.
Procedural history
A District Court jury convicted Martin of assault and battery. The Appeals Court affirmed, reasoning that corroborating testimony reduced the utility of bias inquiry and that the complainant was already shown to be partisan. The Supreme Judicial Court granted further appellate review, reversed the judgment, set aside the verdict, and remanded for a new trial.
Remand instructions
The judgment was reversed, the verdict was set aside, and the case was remanded for a new trial.