JUAN RAMON RODRIGUEZ v. MARION SPEARMAN (2016)

MEMORANDUM*

Davis v. Alaska limits a trial court's discretion to preclude cross-examination that directly relates to an eyewitness's possible biases or motivations to lie. 415 U.S. 308, 317 (1974). But “trial judges retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other things, harassment, prejudice, confusion of the issues” or relevance. Delaware v. Van Arsdall, 475 U.S. 673, 679 (1986). In this case, the California Court of Appeal reasonably concluded that the victim's lie about a collateral matter did little to shed light on her possible motivations to lie about Rodriguez and that “delving into the issue [would be] more prejudicial and confusing than probative.” Accordingly, the state appellate court's rejection of Rodriguez's Confrontation Clause claim was not contrary to or an unreasonable application of clearly established law. See 28 U.S.C. § 2254(d)(1).

AFFIRMED.