concurring in the result:
I join the majority’s analysis of the duty of states to provide meaningful argument under Teague v. Lane, 489 U.S. 288, 109 S.Ct. 1060, 103 L.Ed.2d 334 (1989). I also concur in the result reached by the majority. I write separately because I disagree with the majority’s conclusion that the state courts here adopted a not unreasonable application of clearly established federal law.
Arredondo’s trial was, at bottom, a credibility contest between Arredondo and his alleged victim, Reed, that came down to this question: Which of these men threw the first punch and, therefore, was more likely the aggressor in the fight that ensued in Reed’s room? To help answer that question, Arredondo sought to call Jeffrey Hansen as a witness. Hansen was the only person at trial, other than Arredondo and Reed, who could offer the jury any direct perspective on this critical issue. Nevertheless, the trial judge excused Hansen from testifying, because Hansen planned to invoke the privilege against ■self-incrimination in response to certain questions on cross-examination by the prosecution. The California Court of Appeal affirmed.
Arredondo argues in part that the exclusion of Hansen’s testimony was either contrary to, or involved an unreasonable application of, Washington v. Texas, 388 U.S. 14, 87 S.Ct. 1920, 18 L.Ed.2d 1019 (1967). See Williams v. Taylor, 529 U.S. 362, 405-09, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000); 28 U.S.C. § 2254(d)(1). I agree with the majority that the exclusion was not contrary to Washington. Arredondo does not argue that the court of appeal applied the wrong rule of law. Nor were the facts of Washington indistinguishable from those of his own ease for, as the majority points out, Washington did not involve a witness’s invocation of the privilege against self-inmmination. Maj. op. at 782.
Whether the exclusion of Hansen’s testimony involved an unreasonable application of Washington is a much tougher question. The majority reasons that, because Washington did not involve the assertion of the privilege against self-incrimination, it is not controlling. But “[sjection 2254(d)(1) permits a federal court to grant habeas relief based on the application of a governing legal principle to a set of facts different from those of the case in which the principle was announced.” Lockyer v. Andrade, 538 U.S. 63, 76, 123 S.Ct. 1166, 1175, 155 L.Ed.2d 144 (2003). Indeed, the Supreme Court framed its holding in Washington more broadly than the facts of the case before it, establishing the principle that a state may not “arbitrarily den[y a defendant] ... the right to put on the stand a witness who was physically and mentally capable of testifying to events that he had personally observed, and whose testimony would have been relevant and material to *785the defense.” Washington, 388 U.S. at 23, 87 S.Ct. 1920.
That principle is surely applicable here. Quite simply, to paraphrase Washington, the state trial court denied Arredondo the right to put on the stand Hansen, a witness physically and mentally capable of testifying to events he had personally observed, whose testimony would have been relevant and material to Arredondo’s defense. The only question is whether the court did so in an objectively unreasonable manner — as always, the devil is in the details.
If Arredondo had sought to compel Hansen to relinquish the privilege and testify to self-incriminatory matters, I would have no trouble joining the majority. As my colleagues point out, “a defendant’s right to present relevant testimony is not without limitation and ‘may, in appropriate cases, bow to accommodate other legitimate interests in the criminal trial process.’ ” Maj. op. at 783 (quoting Chambers v. Mississippi, 410 U.S. 284, 295, 93 S.Ct. 1038, 35 L.Ed.2d 297 (1973)). Indeed, the Washington Court made clear that its holding in no way trumped the privilege. Washington, 388 U.S. at 23 n. 21, 87 S.Ct. 1920.
But Arredondo did not seek to extinguish Hansen’s invocation of the privilege. Rather, he asked the trial judge to compel Hansen’s testimony on nonincriminating matters. The trial judge refused, and the court of appeal affirmed on the rationale that “Hansen’s assertion of the Fifth Amendment on cross-examination would have deprived the prosecutor of his right to cross-examine and would have resulted in the striking of Hansen’s direct testimony.” People v. Arredondo, No. B132564, at 7 (Cal. Ct.App. June 28, 2000) (mem.). The question, then, is whether Arredondo’s right to present relevant evidence had to bow to the prosecution’s desire to impeach Hansen as to certain matters on- cross-examination.
That is a close question, and it merits close consideration. In habeas cases, “[w]e employ a balancing test for determining whether the exclusion of testimony violates due process.” Alcala v. Woodford, 334 F.3d 862, 884 (9th Cir.2003) (citing Miller v. Stagner, 757 F.2d 988, 994 (9th Cir.1985)). We “weigh the probative value of the evidence, its reliability, whether the trier of fact can evaluate the evidence, whether the evidence is cumulative,' and whether the evidence proves integral to the defense theory in evaluating whether admissible evidence was constitutionally excluded,” as well as the state’s interest in excluding the evidence. Id. (citing Miller, 757 F.2d at 994).
Hansen’s testimony was clearly probative. Hansen was a direct percipient witness to the start of the fight in the hallway outside Reed’s doorway. He would have testified that he saw Reed throw the first punch. Thus, his testimony would have tended to support Arredondo’s claim that Reed, not Arredondo, was the aggressor. Further, by backing part of Arredondo’s story, Hansen’s testimony would also have bolstered Arredondo’s credibility, thus tending to support Arredondo’s account of the events that unfolded inside Reed’s apartment and his claim that he acted in self-defense.
As to reliability, there were no circumstances that rendered Hansen’s testimony inherently unreliable. The prosecution offered no evidence, for example, that Hansen was not on the scene to witness the beginning of the altercation, nor did the prosecution suggest that Hansen’s ability to perceive or recall the events was somehow impaired. Moreover, the record reveals no facts suggesting that Hansen’s testimony would have been self-serving in any way, or that he personally knew either *786Arredondo or Reed, so as to be biased in favor of one or the other. Hansen had apparently even offered to take a lie detector test at one point. As discussed below, the prosecution would have sought to impeach Hansen at trial with prior convictions and a pending alcohol theft charge. But these considerations “did not make his testimony unreliable but instead raised questions about his credibility and the weight his testimony should be accorded. These are issues to be weighed by the jury, not the judge.” Id. at 885.
In addition, there surely can be no doubt that the jury would have been able to evaluate Hansen’s testimony. It presented no complicated or technical issues to navigate and was merely a straightforward narrative of what Hansen witnessed in the hallway of Arredondo’s and Reed’s residential hotel.
Hansen’s excluded testimony also would not have been cumulative, since he was the only eyewitness available to corroborate Arredondo’s account of the start of the altercation. See United States v. Parry, 649 F.2d 292, 296 (5th Cir. Unit B 1981); cf. United States v. Dring, 930 F.2d 687, 690, 695 (9th Cir.1991) (where one witness corroborated defendant’s testimony, the similar testimony of another witness would have been cumulative); United States v. Tafollo-Cardenas, 897 F.2d 976, 979 (9th Cir.1990) (same).
And, finally, if Hansen’s testimony was not essential to Arredondo’s defense, it was quite significant. Even the trial judge acknowledged that Hansen’s testimony would have been helpful to Arredondo, for what was at the heart of this case was whether Arredondo acted in self-defense. If Reed had been shown to be the aggressor, Arredondo’s self-defense theory would have been more plausible. Perhaps nothing speaks more to the importance of Hansen’s testimony than the fact that the prosecution strove so mightily to keep it out— refusing even to stipulate, as defense counsel was willing to do, to Hansen’s prior convictions in order to lessen the need for Hansen to invoke the privilege.
Of course, that all of these factors weigh in Arredondo’s favor is not conclusive. We must also take account of the state’s interests, Alcala, 334 F.3d at 884, for “[ejven relevant and reliable evidence can be excluded when the state interest is strong,” Perry v. Rushen, 713 F.2d 1447, 1450 (9th Cir.1983). The court of appeal concluded that, had Hansen testified and invoked the privilege against self-incrimination in response to the prosecution’s cross-examination, the trial court would have had to strike all of Hansen’s testimony, thus wasting the time of the jury and the court. The court of appeal reasoned that striking the entirety of Hansen’s testimony would have been necessary because the state would not have been able to openly probe certain aspects of Hansen’s credibility.
That assertion does not stand for two reasons: It isn’t entirely true and, even if it were true, striking all of Hansen’s testimony would still have been an extreme sanction unjustified in light of Arredondo’s constitutional right to present a defense. The state indicated that it would have sought to impeach Hansen’s testimony on two bases — that Hansen had four prior convictions and that a charge of alcohol theft was pending against him.1 As to the *787prior convictions, the state had two alternatives open to it, other than cross-examining Hansen. First, the defense offered to stipulate to those convictions; the prosecution refused. Second, the prosecution could have introduced the' judgments of Hansen’s prior convictions. See Cal. Evid. Code § 788 (“For the purpose of attacking the credibility of a witness, it may be shown by the examination of the witness or by the record of the judgment that he has been convicted of a felony ....”) (emphasis added). Of course, there is a strategic value to having a jury hear impeaching words come from the mouth of the witness himself, but the bottom line is that the state would not have been prevented from impeaching Hansen with his prior convictions.
All that really hung in the balance for the state, then, was whether it could impeach Hansen with the circumstances that formed the basis of his pending charge. The prosecution could have introduced this evidence as proof that Hansen had committed a crime of moral turpitude, and did seek to use it to impeach Hansen’s statement to Arredondo’s investigator that Hansen did not know Reed because he did not associate with alcoholics. Or, to dispense with the legalese, the prosecution wanted to tell the jury that Hansen was a thief and a drunk and thus not believable.
Even assuming that this proposition would have carried any real weight with the jury, it was objectively unreasonable for the trial court to excuse Hansen’s testimony and for the court of appeal to affirm. The prosecution had available a means to introduce Hansen’s prior convictions by documentary evidence rather than by cross-examination. The prosecution further remained free to test the reliability and truth of Hansen’s testimony by exploring the circumstances under which he witnessed the events in question. And, finally, the other factors under Miller fairly outweigh the prosecution’s desire to further impeach Hansen’s credibility with the circumstances of his pending charge. This is so because the issue of Hansen’s credibility, while important, did not go to the heart of the matter to which Hansen was testifying. The facts underlying Hansen’s pending alcohol theft charge had no bearing on what he saw in the hotel hallway. Hansen’s credibility was, in other words, a collateral issue. See United States v. Gould, 586 F.2d 216, 222 (8th Cir.1976); United States v. Brierly, 501 F.2d 1024, 1027 (8th Cir.1974); Monsoor v. Gagnon, 497 F.2d 1126, 1130 (7th Cir.1974); United States v. Norman, 402 F.2d 73, 77 (9th Cir.1968); United States v. Cardillo, 316 F.2d 606, 611 (2d Cir.1963); Bd. of Trustees v. Hartman, 246 Cal.App.2d 756, 764-65, 55 Cal.Rptr. 144 (1966); cf. 8 John Henry Wigmore, Evidence § 2276, at 457 (McNaughton rev., 1961) (“A witness of course does not, simply by testifying (and ‘putting his veracity in issue’), waive his privilege with respect to his criminal acts relevant only to impeach his credibility.”). And the striking of a witness’s entire testimony is a drastic measure that may be unmerited when the witness invokes the privilege on cross-examination as to collateral matters.2 See Denham v. Deeds, 954 *788F.2d 1501, 1504 (9th Cir.1992) (noting in habeas ease that exclusion of testimony of defense witness who invokes privilege on collateral matters may be impermissible); United States v. Esparsen, 930 F.2d 1461, 1469 (10th Cir.1991) (noting that it is improper to, strike testimony in analogous case of prosecution witness who invokes privilege as to collateral matters); United States v. Lord, 711 F.2d 887, 892 (9th Cir.1983) (holding in direct-review case that striking defense witness testimony was erroneous when witness invoked privilege on collateral issue); Monsoor, 497 F.2d at 1129-30 (holding in habeas case that “it is constitutionally impermissible to strike relevant and competent direct examination testimony where a defense witness on cross-examination invokes the privilege against self-incrimination with respect to collateral questions which relate only to his credibility and do not concern the subject matter of his direct examination”). But see Williams v. Borg, 139 F.3d 737, 741 (9th Cir.1998) (holding in habeas case that “[t]he Constitution does not give a defendant a right to testify without subjecting himself to cross-examination which might tend to incriminate him”).3
Of course, these cases are not clearly established federal law from which Arre-dondo can draw the constitutional principle that he alleges was violated in his trial and, thus, as the majority recognizes, do not by themselves mandate that his conviction be vacated. Hernandez v. Small, 282 F.3d 1132, 1140 (9th Cir.2002). But neither are these cases irrelevant, for circuit law may be “persuasive authority” on the question of whether a state court’s determination was unreasonable, Clark v. Murphy, 331 F.3d 1062, 1069 (9th Cir.2003), and these cases remind us that a collateral issue, such as credibility, may be important and yet nonetheless must sometimes be subordinated to the need of the factfin-der to hear relevant evidence.
Because the state’s interest in impeaching Hansen on cross-examination was outweighed by the other factors under Miller, I would hold that the California Court of Appeal’s decision was an objectively unreasonable application of Washington. Ultimately, however, the error committed by the trial court cannot provide the basis for habeas relief, as it was harmless. The jury heard both Arredondo and Reed testify. Reed admitted that he was the first to make physical contact by pushing Arre-dondo with his hands, making the question of who threw the first punch less significant. The jury also heard evidence that the knife Arredondo claims Reed wielded was later found in Arredondo’s girlfriend’s apartment, consistent with Arredondo’s story that he took away the knife after Reed passed out. This evidence corrobo*789rated Arredondo’s version of events. Finally, the jury also heard Arredondo’s investigator testify that Reed had told him that Reed was drunk at the time of the fight, may have used a knife against Arre-dondo and thought he was missing a knife. The jury thus had the opportunity to weigh Arredondo’s story, evidence corroborating it and the apparent absence of any wounds on his part, against Reed’s account and the documented injuries he suffered that required hospitalization. In light of the evidence the jury heard, the exclusion of Hansen’s testimony likely did not have a “ ‘substantial and injurious effect’ ” on the verdict. Brecht v. Abrahamson, 507 U.S. 619, 623, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993) (quoting Kotteakos v. United States, 328 U.S. 750, 776, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946)).
Because I believe exclusion of Hansen’s testimony was harmless, I concur in the result reached by the majority. In addition, I join my colleagues’ analysis of Teague v. Lane, 489 U.S. 288, 109 S.Ct. 1060, 103 L.Ed.2d 334 (1989). Beyond that, I cannot go.
As a final note, I distance myself from the majority’s parting observation that “the defense is not without options in these circumstances [such as Arredondo’s], for immunity may also be sought for the witness.”. Maj. op. at 784. Certainly defense counsel may seek immunity, but this will give little. consolation to criminal defendants in California. In California, most requests for immunity will fall under section 1324 of the Penal Code, which provides a means by which a prosecuting agency can seek immunity for a state witness.4 1 B.E. Witkin & Norman L. Epstein, California Criminal Law § 231, at 602 (3d ed.2000). It does not provide that a defendant has the right to obtain immunity for witnesses in aid of his defense. As explained in People v. Pineda, 30 Cal.App.3d 860, 106 Cal.Rptr. 743 (1973), overruled on other grounds by Leversen v. Superior Court, 34 Cal.3d 530, 539 n. 4, 194 Cal.Rptr. 448, 668 P.2d 755 (1983), “prosecuting attorneys are vested with discretion in requesting immunity and the state is under no obligation to make a witness available to testify for a defendant by granting him immunity from prosecu*790tion.” Id. at 868 (internal citations omitted); see also Daly v. Superior Court, 19 Cal.3d 132, 146, 137 Cal.Rptr. 14, 560 P.2d 1193 (1977); People v. Thompson, 145 Cal.App.3d 918, 923-25, 193 Cal.Rptr. 782 (1983). In light of California law, we can hardly hold defense counsel’s failure to request immunity for Hansen against Ar-redondo. Moreover, as a practical matter, the prosecution in this ease seemed particularly obdurate. Given the state’s unwillingness to stipulate even to Hansen’s prior convictions, as suggested by defense counsel, a request of immunity for Hansen would in all likelihood have been futile.
. In addition, Hansen's lawyer .expressed concern that Hansen could later be prosecuted for perjury, and the state trial judge queried whether the terms of Hansen's parole might prohibit his presence at the hotel where the fight between Arredondo and Reed took place. Neither ground is valid in our analysis. A witness cannot invoke the privilege out of fear of a perjury charge as to a statement not yet made. United States v. Vavages, 151 *787F.3d 1185, 1192 (9th Cir.1998). Further, any reasoning based on the terms of Hansen’s parole would be improper. The trial court only speculated about the conditions of Hansen's parole and never made a finding as to the actual terms. Indeed, Hansen’s lawyer professed ignorance as to such details during the first hearing on whether Hansen would testify and never raised the parole issue during the second hearing.
. The court of appeal cited People v. Hecker, 219 Cal.App.3d 1238, 268 Cal.Rptr. 884 (1990), and People v. Reynolds, 152 Cal.App.3d 42, 199 Cal.Rptr. 379 (1984), for the proposition that “Hansen’s assertion of the *788Fifth' Amendment on cross-examination would have deprived the prosecutor of his right to cross-examine and would have resulted in the striking of Hansen's direct testimony.” People v. Arredondo, No. B132564, at 7 (Cal. Ct.App. June 28, 2000) (mem.). These cases do commit the decision to strike testimony, after the witness has invoked the privilege on cross-examination, to the discretion of the trial judge. However, even these cases caution that such a measure must be undertaken prudently. Reynolds, 152 Cal.App.3d at 47-48, 199 Cal.Rptr. 379 ("In light of the critical right involved, the trial court should also realize that striking a defendant's entire testimony is a drastic solution, which is to be used after less severe means are considered.”); Hecker, 219 Cal.App.3d at 1248, 268 Cal.Rptr. 884 (same as to defense witness, citing Reynolds).
. All Williams held was that the distinction between collateral and non-collateral matters is not by itself of constitutional magnitude, at least as to criminal defendants who take the stand on their own behalf. Williams, 139 F.3d at 741-43. The distinction may nonetheless be relevant in balancing the factors under Miller.
. That provision states in its entirety:
In any felony proceeding or in any investigation or proceeding before a grand jury for any felony offense if a person refuses to answer a question or produce evidence of any other kind on the ground that he or she may be incriminated thereby, and if the district attorney of the county or any other prosecuting agency in writing requests the court, in and for that county, to order that person to answer the question or produce the evidence, a judge shall set a time for hearing and order the person to appear before the court and show cause, if any, why the question should not be answered or the evidence produced, and the court shall order the question answered or the evidence produced unless it finds that to do so would be clearly contrary to the public interest, or could subject the witness to a criminal prosecution in another jurisdiction, and that person shall comply with the order. After complying, and if, but for this section, he or she would have been privileged to withhold the answer given or the evidence produced by him or her, no testimony or other information compelled under the order or any information directly or indirectly derived from the testimony or other information may be used against the witness in any criminal case. But he or she may nevertheless be prosecuted or subjected to penalty or forfeiture for any perjury, false swearing or contempt committed in answering, or failing to answer, or in producing, or failing to produce, evidence in accordance with the order. Nothing in this section shall prohibit the district attorney or any other prosecuting agency from requesting an order granting use immunity or transactional immunity to a witness compelled to give testimony or produce evidence.
Cal.Penal Code § 1324.