State of Oregon, Respondent on Review v. Tracey Mack Titus, Petitioner on Review

Summary

The court held that the trial court properly excluded cross-examination offered solely to lay a foundation for contradicting a witness on a collateral matter, but erred under OEC 401 by excluding evidence that the witness threatened a defense witness because the threat reasonably tended to show bias. The error was harmless because substantial independent and corroborating evidence supported the convictions. The court declined to discuss the hearsay and prior-drug-use assignments because they did not require reversal and further discussion would not benefit the bench or bar.