New Standard for Limiting Impeachment Cross-Examination under the Confrontation Clause: Snowden Four-Factor Test Applied in Hazelett v. State

Introduction

Hazelett v. State, decided by the Supreme Court of Delaware on April 25, 2025, addresses the delicate balance between a criminal defendant’s constitutional right to confront and impeach adverse witnesses and the trial court’s duty to prevent confusing, prejudicial, or collateral detours. Appellant Briana Hazelett was convicted in the Superior Court of several offenses arising from a traffic stop: possession of a firearm by a prohibited person, drug possession, driving with a suspended license, and failure to signal a turn. On appeal, Hazelett argued that the trial court unduly restricted her cross-examination of the State’s chief investigator, Corporal Leonard Moses, by (1) improperly suggesting defense counsel must disclose impeachment strategy in advance, (2) limiting inquiry into a prior inconsistent statement in another case (State v. Whittle), and (3) barring challenges to the legality of the traffic stop. The Supreme Court considered whether these restrictions violated Hazelett’s Confrontation Clause rights and whether any error was harmless.

Summary of the Judgment

The Supreme Court of Delaware affirmed the Superior Court’s judgment in full. The Court held:

The trial court did not violate Hazelett’s constitutional right to present a complete defense or to cross-examine adverse witnesses. It properly applied the four-factor Snowden v. State test to balance the right to impeach against the risks of unfair prejudice, confusion, or undue delay.
The trial court’s limitation preventing counsel from arguing that the traffic stop was illegal did not preclude Hazelett from challenging the sufficiency of the evidence on the turn-signal violation. Any uncertainty counsel had about the ruling was not preserved by objection or request for clarification at trial.
Any suggestion by the trial court that the defense must disclose impeachment materials in advance was error but harmless. The jury received sufficient evidence to appraise Corporal Moses’s credibility, and his testimony was corroborated by other officers and body-worn camera footage.

Analysis

1. Precedents Cited

The Court’s analysis relied heavily on two landmark decisions:

Snowden v. State, 672 A.2d 1017 (Del. 1996) Snowden articulated a four-factor test to guide trial courts when limiting cross-examination intended for impeachment. The factors are:
- Whether the witness’s testimony is crucial to the State’s case.
- The logical relevance of the impeachment evidence to the issues before the jury.
- The danger of unfair prejudice, confusion of the issues, or undue consumption of time.
- Whether the evidence is cumulative of other impeachment evidence already before the jury.
Delaware v. Van Arsdall, 475 U.S. 673 (1986) The U.S. Supreme Court held that trial judges have broad discretion to impose reasonable limits on cross-examination under the Confrontation Clause to avoid harassment, prejudice, confusion, or repetitive questioning.

The Court also referred to Wilson v. State (constitutional review of cross-examination limits) and Crane v. Kentucky (defendant’s right to present a complete defense).

2. Legal Reasoning

The Supreme Court conducted a two-step analysis:

a. Constitutional vs. Non-Constitutional Limits

Restrictions on cross-examination that implicate the Confrontation Clause are reviewed de novo; non-constitutional restrictions are reviewed for abuse of discretion. The Court concluded that the limitations at issue were constitutional in nature because they touched on Hazelett’s right to confront witnesses.

b. Application of the Snowden Factors

The Court found that the trial court systematically applied each Snowden factor:

Crucial Testimony: Although Corporal Moses was the lead investigator, much of his testimony was corroborated by other officers and recorded on body-worn camera. Only the initial observation of the stop and turn-signal violation lacked camera coverage, reducing the criticality of impeaching him.
Logical Relevance: Inconsistent statements in the Whittle case bore directly on Moses’s general credibility, but only for the unrecorded portions of his testimony. Full exploration risked misleading the jury into relitigating Whittle.
Risk of Prejudice/Confusion: Detailed inquiry into why Whittle was dismissed could have confused the jury or spawned a trial-within-a-trial, particularly since the dismissal rested on insufficient evidence rather than a finding of dishonesty.
Cumulativeness: This was the first opportunity to present such impeachment evidence in the case, so it was not cumulative—but that cut both ways, indicating the need for careful limitation.

c. Harmless-Error Review

Even assuming the trial court erred by implying an obligation to disclose impeachment materials in advance, that error was harmless. Defense counsel secured admission of all relevant prior inconsistent statements, and the jury had ample evidence—unaffected by the limitation—to assess Moses’s credibility.

3. Impact

Hazelett v. State clarifies how Delaware trial courts must employ the Snowden framework when faced with proposed cross-examination that rests on prior inconsistent statements or collateral matters. Key takeaways include:

Trial judges should explicitly articulate each Snowden factor on the record when restricting impeachment cross-examination.
Defendants may impeach police officers on prior inconsistent statements, but courts may reasonably confine the scope to avoid collateral trials and jury confusion.
Any suggestion that defense counsel must furnish impeachment materials in advance is error under Delaware’s discovery rules—and will be deemed harmless only if the jury still received the core impeachment evidence.

Future cases will likely cite Hazelett for the proposition that limiting impeachment cross-examination does not automatically violate the Confrontation Clause if the four Snowden factors are balanced and the error, if any, is harmless.

Complex Concepts Simplified

Confrontation Clause: A provision in the Sixth Amendment guaranteeing a criminal defendant the right to confront (i.e., cross-examine) witnesses against them.
Impeachment: The process of challenging a witness’s credibility, often by introducing prior inconsistent statements or evidence of bias.
Snowden Four-Factor Test: A structured approach for judges to decide whether to permit or limit impeachment cross-examination:
1. Is the witness’s testimony crucial?
2. Is the impeachment evidence directly relevant?
3. Will it unfairly prejudice, confuse, or delay?
4. Is it merely cumulative?
Harmless Error: A legal standard assessing whether an error at trial was so minor that it did not affect the verdict.
Collateral Trial Risk: The danger that cross-examination will stray into facts of an entirely separate incident or case, distracting the jury from the central issues.

Conclusion

Hazelett v. State reaffirms that a defendant’s right to cross-examine adverse witnesses is fundamental but not unfettered. By applying the Snowden four-factor test, the Supreme Court endorsed reasonable trial-court limits on impeachment cross-examination when necessary to prevent jury confusion or undue prejudice. The decision underscores the need for clear, on-the-record weighing of each Snowden factor and confirms that any inadvertent suggestion of reciprocal discovery obligations is harmless if the defendant still secures meaningful impeachment evidence. Hazelett thus shapes Delaware’s cross-examination jurisprudence and guides trial courts in preserving the integrity of the Confrontation Clause while maintaining orderly, focused trials.