Does a ruling by a trial court that adversely affects a litigant's evidentiary presentation constitute a constitutional error?

Though "[t]he failure to accord a party litigant his constitutional right to due process is reversible per se" (In re Marriage of Carlsson (2008) 163 Cal.App.4th 281, 293 (Marriage of Carlsson)), not every ruling by a trial court that adversely affects a litigant's evidentiary presentation rises to the level of constitutional error. On the contrary, the trial court unquestionably "has the power to rule on the admissibility of evidence, exclude proffered evidence that is deemed to be irrelevant, prejudicial or cumulative and expedite proceedings which, in the court's view, are dragging on too long without significantly aiding the trier of fact." (Id. at p. 291.) It is only when the court abuses this discretion " 'in such manner as to prevent a full and fair opportunity to the parties to present all competent, relevant, and material evidence bearing upon any issue properly presented for determination' " that a litigant's due process rights are implicated. (Elkins v. Superior Court (2007) 41 Cal.4th 1337, 1357)

The trial court has broad authority and a statutory duty to control trial proceedings, including the introduction and exclusion of evidence. (Evid. Code, 320, 352.) Evidence Code section 765 directs the trial court to "exercise reasonable control over the mode of interrogation of a witness so as to make interrogation as rapid, as distinct, and as effective for the ascertainment of the truth, as may be, and to protect the witness from undue harassment or embarrassment." Because the trial court has the power and the duty to exclude inadmissible, duplicative or unduly prejudicial evidence, "it is well established that where questions are asked which are improper, the court acts within the scope of its duty in refusing to allow them to be answered, even though no objection [is] made.

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[Citations.]" (People v. White (1954) 43 Cal.2d 740, 747; see also People v. Clark (1992) 3 Cal.4th 41, 144.)