Preventing Defendant From Cross-examining a Crucial Witness
In Chambers, Mississippi's evidentiary rules prevented the defendant from cross-examining a crucial witness, McDonald, who had confessed to the murder with which the defendant was charged. (Chambers, supra, 410 U.S. at pp. 291-294.)
Those evidentiary rules recognized a hearsay exception for declarations against pecuniary interest but not ones against penal interests. (Id. at p. 299.)
Evidence that McDonald made statements confessing to being the murderer was therefore excluded as hearsay.
"Although perhaps no rule of evidence has been more respected or more frequently applied in jury trials than that applicable to the exclusion of hearsay, exceptions tailored to allow the introduction of evidence which in fact is likely to be trustworthy have long existed. The testimony rejected by the trial court here bore persuasive assurances of trustworthiness and thus was well within the basic rationale of the exception for declarations against interest. That testimony also was critical to Chambers' defense. In these circumstances, where constitutional rights directly affecting the ascertainment of guilt are implicated, the hearsay rule may not be applied mechanistically to defeat the ends of justice." (Id. at p. 302.)
Chambers, however, "was an exercise in highly case-specific error correction." (Montana v. Egelhoff (1996) 518 U.S. 37, 52.) "The holding of Chambers--if one can be discerned from such a fact-intensive case--is certainly not that a defendant is denied 'a fair opportunity to defend against the State's accusations' whenever 'critical evidence' favorable to him is excluded, but rather that erroneous evidentiary rulings can, in combination, rise to the level of a due process violation." (Id. at p. 53; accord People v. Gonzales (2012) 54 Cal.4th 1234, 1258-1259 exclusion of evidence that the defendant's wife had a family history of child abuse did not violate the defendant's right to present a defense; People v. Ayala (2000) 23 Cal.4th 225, 269 the defendant did not have either a constitutional or a state law right to present exculpatory but unreliable hearsay evidence inadmissible under any statutory exception to the hearsay rule.)