United States v. Williams

MEMORANDUM *

Robert Lee Williams, Jr. appeals his jury conviction for assaulting a federal officer in violation of 18 U.S.C. § 111 . Williams was involved in an altercation with the security guard at a Lancaster, California Social Security office. The struggle began inside the office and ended outside, where several witnesses saw Williams repeatedly strike the guard with a night stick.

On appeal, Williams contends the district court violated his Sixth Amendment rights when it limited his cross-examination of two government witnesses, Eason and Garcia. We review a trial court’s limitation on cross-examination for an abuse of discretion, but review de novo whether such limitations violate the Sixth Amendment confrontation clause. United States v. James, 139 F.3d 709, 713 (9th Cir.1998). Any violation of the confrontation clause is subject to harmless error analysis. Delaware v. Van Arsdall, 475 U.S. 673, 684 , 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986)

I. Eason

We need not decide whether Williams’ confrontation rights were violated by the court’s limitation on the cross-examination of Eason, because any potential error was harmless. In determining whether a violation is harmless,…