California, United States of America
The following excerpt is from People v. Barron, E052515 (Cal. App. 2012):
Even if we were to find constitutional error, it would be harmless beyond a reasonable doubt. Improperly denying a defendant the opportunity to cross-examine an adverse witness on matters reflecting on the witness's credibility may be subject to the harmless error standard set forth in Chapman v. California, supra, 386 U.S. at p. 24; "'[h]owever, not every restriction on a defendant's desired method of cross-examination is a constitutional violation. . . .'" (People v. Chatman (2006) 38 Cal.4th 344, 372.) "A trial court's limitation on cross-examination pertaining to the credibility of a witness does not violate the confrontation clause unless a reasonable jury might have received a significantly different impression of the witness's credibility had the excluded cross-examination been permitted. [Citations.]" (People v. Quartermain (1997) 16 Cal.4th 600, 623-624.) Accordingly, once we conclude, post, that there is no reasonable probability that the admission of this evidence would have changed the result, we must likewise conclude there was no confrontation clause violation.
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