State v. Quinlan
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The Supreme Court affirmed Defendant's conviction of incest, holding that the district court did not err by precluding Defendant from introducing extrinsic evidence to challenge the victim's credibility.
On appeal, Defendant argued that his defense was prejudiced because he was prohibited from demonstrating the victim's bias or motive to testify falsely and that the court's evidentiary ruling violated his right to confrontation under the Sixth Amendment of the United States Constitution and Mont. Const. art. II, 24. The Supreme Court affirmed, holding (1) the district court did not misapply the rules or abuse its discretion in its ruling on the admissibility of evidence; and (2) the district court properly exercised its discretion by imposing reasonable limits on Defendant's evidentiary inquiries.
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