People v. Bowman

ROYIRA, Justice,

dissenting.

I respectfully dissent from part II of the majority opinion. Trial courts have broad discretion to control the mode and extent of the presentation of evidence. Unless that discretion is clearly abused, the rulings should not be disturbed on review. People v. Cole, 654 P.2d 830 (Colo.1982); People v. Henry, 195 Colo. 309, 578 P.2d 1041 (1978); People v. Bynum, 192 Colo. 60, 556 P.2d 469 (1976). Constitutional rights to cross-examine witnesses are not absolute and may be limited to accommodate competing interests. Chambers v. Mississippi, 410 U.S. 284, 295, 93 S.Ct. 1038, 1045-46, 35 L.Ed.2d 297 (1973); Cole, 654 P.2d at 833.

As I read the majority opinion, two factors lead to the conclusion that the trial judge abused his discretion in limiting defendant’s cross-examination of Anthony To-liver. First, the trial judge’s decision to prohibit defendant’s proposed questions about juvenile proceedings pending against Anthony prevented the jury from evaluating whether Anthony’s testimony was influenced by a promise, hope, or expectation of leniency with respect to those juvenile proceedings. But, competing interests favor the trial judge’s decision. In general, evidence of pending charges should not be admitted. People v. Robles, 183 Colo. 4, 6-7, 514 P.2d 630, 631 (1973); see section 13-90-11, C.R.S.1973. This interest is particularly strong when juvenile proceedings are involved. See section 19-1-109(2), C.R. S.1973.

The majority cites two cases, People v. King, 179 Colo. 94, 498 P.2d 1142 (1972), and People v. Pate, 625 P.2d 369 (Colo.1981), to support its weighing of the competing interests in favor of finding that the trial judge abused his discretion. These cases are distinguishable. King involved the testimony of a paid, planted informant. In contrast, law enforcement authorities had nothing to do with Anthony’s presence during the events that formed the basis of his testimony. Anthony’s mother and brother were killed in the fire allegedly set by defendant, who is Anthony’s stepfather. The inference that Anthony’s testimony may have been influenced by a promise, hope, or expectation of leniency with respect to independent proceedings against him is much weaker than the inference in King.

A similar analysis applies to Pate. There, the dispositional hearings of the juvenile witnesses were purposely postponed until after the defendant’s trial. The juveniles admittedly participated in the crimes charged against the defendant. Pate, 625 P.2d at 369. The inference that these juvenile witnesses may have been influenced by promises, hopes, or expectations of leniency vis-a-vis their own pending proceedings is much stronger than in the instant case, since no similar links were shown with respect to Anthony’s pending proceedings.

The trial judge in the instant case refused to allow this line of cross-examination because, inter alia, defendant had not laid an adequate foundation. Under these circumstances, the trial judge was correct in requiring more facts linking Anthony to possible promises, hopes, or expectations of leniency in the proceedings against him before balancing the competing interests in favor of allowing the cross-examination in question.

Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974), is also distinguishable. As the trial judge here points out, Davis involved a juvenile who had been adjudicated delinquent and placed on probation prior to Davis’ trial. Davis, 415 U.S. at 311, 94 S.Ct. at 1108. The inference that Anthony’s testimony might have been influenced by fears of jeopardizing his position is weaker since he had not been adjudicated delinquent, but had been merely charged with an offense and involved with an informal diversion program at the time of Bowman’s trial.

*1381The second factor relied upon by the majority relates to the restrictions placed on Anthony by his mother and the defendant. The majority maintains that defendant should have been able to explore the restrictions during cross-examination to develop two theories. First, Anthony may have testified falsely against the defendant because of the malice that Anthony felt due to the restrictions. Second, Anthony may have set the fire in retaliation and testified falsely against his stepfather to divert suspicion from himself.

During cross-examination, a trial court may exercise its sound discretion to preclude inquiries that have little bearing on the witness’ credibility but would substantially impugn his moral character. Cole, 654 P.2d at 832; People v. Taylor, 190 Colo. 210, 545 P.2d 703 (1976). In his offer of proof, the specific restrictions mentioned by defendant’s counsel were not onerous: Anthony could not have friends at home and he had to stay home after school. It seems highly unlikely that these parental restrictions would motivate Anthony to kill his mother and his brother, or to testify falsely against his stepfather in a first-degree murder prosecution. Thus, the trial judge could reasonably conclude that the inquiries about the restrictions would have little bearing on Anthony’s credibility.

For the reasons stated above, I conclude that the trial judge did not clearly abuse his discretion in limiting the cross-examination of Anthony Toliver. Defendant’s constitutional right to confront and to cross-examine witnesses was not abridged. Therefore, I would not reverse defendant’s convictions on that basis.