State v. Prange

Evidence of bias may be held relevant where 1) it demonstrates a witnesses' motivation to lie, and 2) is not used to prove the witnesses’ propensity to act in conformity with prior bad acts. Additionally, a party may impeach a witness for bias through evidence of the witness’s relationship with another, where the bias resulting from the relationship is a matter of reasonable inference rather than speculation.

Defendant was convicted of menacing and disorderly conduct. Defendant sought to introduce evidence of bias on behalf of the victim by impeaching her as a witness. Defendant intended to do this by impeaching that victim’s wife. She called defendant’s daughter names, and falsely notified police that defendant’s daughter shot the victim’s house with a pellet gun. The trial court overruled his attempt to impeach the witness on the grounds that the information was not relevant, and impermissible prior bad acts evidence are not admissible to show conformity. On review by the Court of Appeals, the Court found that the pellet gun incident was relevant because 1) it demonstrated the victim’s motivation to lie, and 2) was not used to prove the witnesses’ propensity to act in conformity with prior bad acts. The Court concluded that the bias due to the relationship was a matter of inference rather than speculation and was therefore admissible. Reversed and remanded