Carroll v. State (1996)

In Carroll v. State, 916 S.W.2d 494 (Tex. Crim. App. 1996), the court of criminal appeals held that a trial court abused its discretion by preventing the defendant from cross-examining a State's witness about pending criminal charges. Id. at 500. The court also observed that in the event of a conflict between the rules of evidence and the constitutional right of confrontation, the latter would prevail. Id. at 501. The Court held that the constitutional right of confrontation is violated when appropriate cross-examination is limited. Id. at 497. It held that, within the broad scope of appropriate cross-examination, is questioning concerning criminal charges pending against a witness and over those which those in need of the witness's testimony might be empowered to exercise control. Id. at 498. The court subsequently cited authority from the United States Supreme Court to the effect that the trial court might exercise discretion to prevent prejudice or confusion of the issues. Id.