On Point: a. Bias

State v. Jon P. Barreau, 2002 WI App 198, PFR filed 8/12/02
For Barreau: Glenn C. Reynolds

Holding: A witness’s pending criminal charges are relevant to bias, even absent promises of leniency. ¶55. In this instance, the trial court prohibited cross-examination about whether the witness was receiving benefits from the state for his testimony, but only after the witness testified outside the jury’s presence that there were none.

State v. Tito J. Long, 2002 WI App 114, PFR filed 5/23/02
For Long: Ann T. Bowe

Issue/Holding: Evidence of gang affiliation is admissible (if state shows that defendant in fact was affiliated) to show witness’ bias, per United States v. Abel, 469 U.S. 45, 52 (1984). ¶¶17-19.