Trial Decisions—Cross-Examination

"We apply the abuse of discretion standard when reviewing a district court's evidentiary rulings.  With respect to evidentiary rulings, we afford the district courts 'broad discretion . . . to limit the scope of cross-examination to those issues it determines are relevant to trial.'"  State v. Wilson, 2007 MT 327, ¶ 19, 340 Mont. 191, 172 P.3d 1264 (citing State v. Beavers, 1999 MT 260, ¶ 20, 296 Mont. 340, 987 P.2d 371).

"We review a district court's evidentiary rulings for an abuse of discretion.  If evidence has been improperly admitted, however, we will find reversible error based on prejudice to the defendant where there is a reasonable probability that the inadmissible evidence might have contributed to the conviction."  State v. Gowan, 2000 MT 277, ¶ 9, 302 Mont. 127, 13 P.3d 376 (holding the District Court did abuse its discretion when it allowed a prosecutor to open the door to character evidence when crossing a defense witness).  See also State v. Nelson, 2002 MT 122, ¶¶ 9, 11, 310 Mont. 71, 48 P.3d 736.