Washington v. Orn (Majority)
Annotate this CaseIn this case, the issue presented for the Washington Supreme Court's review was whether the trial court violated petitioner Nicholas Conan Orn’s rights to confrontation and to present a complete defense when it barred him from cross-examining the State’s key witness to expose the witness’s bias. Orn was charged with attempted first-degree murder after he shot and wounded Thomas Seamans in Kent, Washington in 2016. At trial, Orn sought to cross-examine Seamans on the nature and extent of Seamans’s work as a confidential informant for the Kent Police Department (KPD). But the trial court limited Orn’s proposed line of cross-examination to a single, misleading question: “[I]sn’t it true that . . . you have actually worked with the Kent Police?” The Court of Appeals affirmed in an unpublished opinion, and the Supreme Court granted review. The Supreme Court reiterated its holding in prior decisions that relevant bias evidence is admissible unless the State articulates a compelling interest for excluding it. Furthermore, the Court held that the single question the trial court allowed the defense to ask intros case "tended to obfuscate, rather than highlight, any potential bias. As a result, the trial court’s decision to exclude all other evidence related to that informant agreement violated constitutional protections and constituted an abuse of discretion." The Court found the State, however, carried its burden of proving beyond a reasonable doubt that this constitutional error was harmless. Accordingly, the trial court's judgment was affirmed.
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