Pettie v. State

Evidence of the bias of a witness is always relevant. Davis v. Alaska, 415 U.S. 308, 316, 94 S.Ct. 1105, 1110, 39 L.Ed.2d 347 (1974); Waldron v. State, 62 Md.App. 686, 695-96, 491 A.2d 595 (1985); Biggs v. State, 56 Md.App. 638, 645-46, 468 A.2d 669 (1983), cert. denied, 299 Md. 425, 474 A.2d 218 (1984). Consequently, matters which tend to prove a witness’ bias may be the subject of cross-examination or extrinsic evidence as to such matters may be admissible to impeach the witness. Biggs, 56 Md.App. at 646, 468 A.2d 669. Recognizing that this is so, but, analogizing bias evidence to evidence…