Gonzalez v. State

Summary

The Supreme Court of Maryland held that the trial court improperly barred cross-examination of the assault victim about her U visa application because the defense established a sufficient factual foundation suggesting that she could have had an interest in obtaining or preserving immigration benefits through cooperation with the prosecution. The Court nevertheless affirmed because the error was harmless beyond a reasonable doubt, given the defendant’s admissions, corroborating testimony and physical evidence, and the consistency of the victim’s account with her initial report. The Court did not decide whether the probative value of the proposed questioning was substantially outweighed by undue prejudice or confusion because that issue was not decided below or presented in the certiorari petition.