What is the test for "relevant" evidence in a criminal case?

California, United States of America


The following excerpt is from People v. Camberos, B258188 (Cal. App. 2016):

"To be relevant, evidence must have some 'tendency in reason to prove or disprove any disputed fact that is of consequence to the determination of the action.' (Evid. Code, 210.) This definition includes evidence 'relevant to the credibility of a witness.' [Citations.]" (People v. Contreras (2013) 58 Cal.4th 123, 152.) "Conversely, a matter is 'collateral' if it has no logical bearing on any material, disputed issue. [Citation.] A fact may bear on the credibility of a witness and still be collateral to the case. [Citations.]" (Ibid.) "[T]he trial court has wide latitude . . . to exclude evidence offered for impeachment that is collateral and has no relevance to the action. [Citations.] This exercise of discretion necessarily encompasses a determination that the probative value of such evidence is 'substantially outweighed' by its prejudicial, 'confusing,' or time-consuming nature. [Citations.]" (Ibid.) Moreover, "as long as the excluded evidence would not have produced a "'"'significantly different impression'"'" of the witness's credibility, the confrontation clause and related constitutional guarantees do not limit the trial court's discretion in this regard. [Citations.]" (Ibid.)

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