In Smallwood v. State, 320 Md. 300, 577 A.2d 356 (1990), the defendant was charged with stealing clothing from a man who was delivering it to The Gap, a retail clothing store, in April 1987. Smallwood, supra, 320 Md. at 302. At trial, Smallwood's ex-girlfriend testified against him, stating that, in April 1987, Smallwood gave her clothing that still bore price tags from The Gap. Id. On cross-examination, defense counsel attempted to elicit from the ex-girlfriend that Smallwood had been previously acquitted of two charges of assaulting her. The court found these prior acquittals to be irrelevant and prevented defense counsel from eliciting this information. Id. at 302-03. On appeal, the Court of Appeals characterized the defense's purpose in trying to elicit the prior acquittals as an attempt "to demonstrate for the jury that the witness's motivation for testifying as she did in the instant case stemmed from her failure to obtain convictions in the previous cases." Id. at 304. Thus, the Court concluded that the evidence was relevant toward "revealing possible biases, prejudices, or ulterior motives of the witness as they may relate directly to the issues or personalities in the case at hand." Id. at 309 (quoting Davis v. Alaska, 415 U.S. 308 (1974)). In Smallwood, the potential bias of Smallwood's ex-girlfriend was relevant based primarily on the prior relationship between the witness and the defendant and on the fact that the witness had previously attempted to bring unrelated charges against the defendant.