Gonzalez v. State

Summary

The Supreme Court of Maryland held that the trial court improperly barred cross-examination of the alleged victim about her U visa application because the defense established a sufficient factual foundation for showing potential bias or motive to testify favorably for the prosecution. The court did not decide whether the inquiry's probative value was substantially outweighed by prejudice or confusion because that issue was not decided below or presented in the certiorari petition. It nevertheless affirmed because the error was harmless beyond a reasonable doubt in light of the defendant's admissions, corroborating testimony, medical evidence, photographs, and consistent initial report.