What is the test of relevant evidence in a criminal case?

California, United States of America


The following excerpt is from People v. Knight, 2d Crim. No. B276973 (Cal. App. 2018):

his credibility. He contends that the evidence is irrelevant, improper character evidence, impeachment on collateral issues, unduly prejudicial, and a denial of due process of law pursuant to the United States Constitution. ( 1101, subd. (a), 352; People v. Albarran (2007) 149 Cal.App.4th 214, 230-232 [defendant's due process rights violated by admission of gang-related evidence that was irrelevant, inflammatory, and prejudicial].) Knight asserts that the error is not harmless beyond a reasonable doubt.

Section 210 defines relevant evidence as evidence that has "any tendency in reason to prove or disprove any disputed fact that is of consequence to the determination of the action." The test of relevance is whether the evidence tends to establish a material fact such as identity, intent, or motive. (People v. Tully (2012) 54 Cal.4th 952, 1010.) The trial court has broad discretion to determine the relevance of evidence. (Ibid.)

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