People v. Dyer

In People v. Dyer (1988) 45 Cal.3d 26, the defendant wanted to cross-examine two witnesses about charges against them in matters unrelated to the defendant's trial; the defendant hoped to show their testimony would secure help from the police in the unrelated matters. (Dyer, supra, at pp. 44-45.) During in camera hearings, the witnesses denied any connection between their testimony and the unrelated charges, and these denials were corroborated by other evidence. (Id. at p. 48.) The trial court excluded the proposed cross-examination. (Id. at pp. 44-46.) The Dyer court held the trial court's rulings did not constitute reversible error, reasoning, inter alia, the trial court had wide discretion to limit cross-examination on the grounds of marginal relevance, which did not impact the defendant's rights of confrontation. (Id. at p. 48.) After noting the charges against the two witnesses had been dismissed or reduced before they took the witness stand against the defendant, the court held "in the absence of proof of some agreement which might furnish a bias or motive to testify against the defendant, the fact that each witness had been charged with the commission of unrelated offenses was irrelevant." (Id. at pp. 49-50.)