In Delaware v. Van Arsdall, 475 U.S. 673 (1986), defendant's confrontation rights were violated when the trial court improperly restricted a cross-examination which was designed to show bias on the part of a prosecution witness. ( Id. at p. 674.) The court held that such a violation required a determination of prejudice under Chapman. ( Id. at pp. 681-684.) "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 host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the overall strength of the prosecution's case. " ( Id. at p. 684.) The defense counsel sought to impeach a prosecution witness by questioning him about the dismissal of a criminal charge against him following his agreement to speak to the prosecutor about the charged murder and sought to cross-examine the witness about being questioned in connection with an unrelated homicide that had occurred after the charged murder. (Id. at p. 676.) The court determined: "A criminal defendant states a violation of the Confrontation Clause by showing that he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby 'to expose to the jury the facts from which jurors . . . could appropriately draw inferences relating to the reliability of the witness.' ." (Delaware v. Van Arsdall, supra, 475 U.S. at p. 680.) The court concluded that Van Arsdall had met that burden because a reasonable jury might have received a significantly different impression of the prosecution witness's credibility if defense counsel had been permitted to pursue his proposed line of cross-examination. (Ibid.) As to the standard for reviewing the error, the court stated: "The constitutionally improper denial of a defendant's opportunity to impeach a witness for bias, like other Confrontation Clause errors, is subject to Chapman harmless-error analysis. 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 host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the overall strength of the prosecution's case. " (Delaware v. Van Arsdall, supra, 475 U.S. at p. 684.)The United States Supreme Court stated: "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, the witness' safety, or interrogation that is repetitive or only marginally relevant." The Van Arsdall Court further stated: "A criminal defendant states a violation of the Confrontation Clause by showing that he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby 'to expose to the jury the facts from which jurors . . . could appropriately draw inferences relating to the reliability of the witness' " (Van Arsdall, 475 U.S. at 680). The U.S. Supreme Court articulated that violations of the Confrontation Clause are subject to harmless error analysis as defined in Chapman v. California, 386 U.S. 18 (1967). The Court explained application of the rule in the context of a Confrontation Clause issue: 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 host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the overall strength of the prosecution's case.(Van Arsdall, 475 U.S. at 684.) The Supreme Court discussed the rationale of allowing limits to a defendant's Sixth Amendment right: "It does not follow, of course, that the Confrontation Clause of the Sixth Amendment prevents a trial judge from imposing any limits on defense counsel's cross-examination of a prosecution witness. On the contrary, 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, the witness' safety, or interrogation that is repetitive or only marginally relevant." (475 U.S. at 679 (1986); see also Fed. R. Evid. 403.) "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 host of factors, all readily accessible to reviewing courts. These factors include the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the overall strength of the prosecution's case. " (Id. at p. 684.) In Delaware v. Van Arsdall, there was a denial of the right to effective cross-examination where defendant was barred from any cross-examination about the dismissal of charges against a prosecution witness. The United States Supreme Court spoke to the Sixth Amendment issue in Delaware v. Van Arsdall (1986): "The Confrontation Clause of the Sixth Amendment guarantees the right of an accused in a criminal prosecution 'to be confronted with the witnesses against him.' The right of confrontation, which is secured for defendants in state as well as federal criminal proceedings, 'means more than being allowed to confront the witness physically.' Indeed, '"the main and essential purpose of confrontation is to secure for the opponent the opportunity of cross-examination."' Of particular relevance here, 'we have recognized that the exposure of a witness' motivation in testifying is a proper and important function of the constitutionally protected right of cross-examination.' It does not follow, of course, that the Confrontation Clause of the Sixth Amendment prevents a trial judge from imposing any limits on defense counsel's inquiry into the potential bias of a prosecution witness. On the contrary, 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, the witness' safety, or interrogation that is repetitive or only marginally relevant.... 'The Confrontation Clause guarantees an opportunity for effective cross-examination, not cross-examination that is effective in whatever way, and to whatever extent, the defense might wish.'" The Supreme Court determined that "a criminal defendant states a violation of the Confrontation Clause by showing that he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby 'to expose to the jury the facts from which jurors ... could appropriately draw inferences relating to the reliability of the witness.'" (Delaware v. Van Arsdall, supra, 475 U.S. at p. 680.) In sum, the United States Supreme Court considered whether violations of confrontation rights under the Sixth and Fourteenth Amendments required automatic reversal. In that case the defense sought to elicit testimony regarding bias of a key witness. Specifically, defense counsel wanted to impeach the witness during cross-examination about dismissal of a pending "drunk on the highway" charge after he agreed to speak with the prosecution. Outside the presence of the jury, the witness admitted the charges were dropped in exchange for his testimony. The trial court prohibited defendant from cross-examining the witness about the arrangement under which the charges against him were dropped, relying on a Delaware evidence code section which is substantially similar to our Evidence Code section 352. (Delaware v. Van Arsdall, supra, 475 U.S. at page 676.) The Supreme Court noted "trial courts 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, the witness' safety, or interrogation that is repetitive or only marginally relevant." (Delaware v. Van Arsdall, supra, 475 U.S. at page 679.)