State v. Naudain

Under OEC 401, evidence of a third-party’s racial bias is relevant where it bears a “logical relationship” to, and tends to show a witness’s own views.

The State appealed the reversal and remand of Defendant’s aggravated murder conviction. The State sought review of the Court of Appeals’ determination that questioning about the victim’s racial bias would have been (1) relevant to show the witness’s own bias and (2) not inadmissible under OEC 403 as more prejudicial than probative. On appeal, the State argued that there was no logical connection between the victim’s racial bias and the witness’s racial views and that asking about the victim’s bias “serv[ed] no relevant purpose” except to “tarnish the [victim’s] reputation.” In response, Defendant argued that evidence of the victim’s racial views would show the witness’s willing acquiescence to such beliefs and her own possible prejudices. Under OEC 401, evidence of a third-party’s racial bias is relevant where it bears a “logical relationship” to, and tends to show a witness’s own views. The Court held that evidence of the victim’s racial bias was logically related to the witness’s bias because of their intimate relationship status and living arrangement. Although there may not be such a connection between the views of two people in every case, there was here. The Court reasoned that the evidence would be more probative than prejudicial under OEC 403. The decision of the Court of Appeals is affirmed. The judgment of the circuit court is reversed, and the case is remanded to the circuit court for further proceedings.