State v. Larson (Minn. Sep. 2, 2010)

Evidence at issue: Defense in homicide trial wanted to attack the credibility of an eyewitness’s testimony with his immigration status and the fact that he was in removal proceedings. HELD: Because the defense did not provide any evidence that the witness was given any consideration at his deportation hearing for his testimony in the homicide trial, the district court properly excluded cross examination on the witness’s immigration status and removal proceedings.  The danger of unfair prejudice or of misleading the jury substantially outweighed any probative value. The court noted that such evidence “must not be so attenuated as to be unconvincing” to be sufficiently probative of bias. Defendant was convicted of aiding and abetting first-degree premeditated murder and he appealed. The Court held that defendant did not proffer evidence that had inherent tendency to connect alleged alternative perpetrators with crime and that the trial court acted within its discretion