Supreme Court of Maryland

Gonzalez v. State

May 29, 2024487 Md. 136

Summary

The Supreme Court of Maryland held that the trial court improperly barred cross-examination of the victim about her U visa application because the defense established a sufficient factual foundation showing a potential motive to testify favorably for the prosecution. The court nevertheless affirmed the convictions, concluding beyond a reasonable doubt that the error did not influence the verdict in light of the defendant's admissions, corroborating testimony, medical evidence, photographs, and the victim's consistent 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 for review.